COMMISSION STAFF WORKING DOCUMENT EVALUATION of the impact of EU's agreements on key environmental aspects, including the climate
Date: 2025-12-19
Institutions: Directorate-General for Trade and Economic Security, European Commission
Subjects: EU growth strategy, climate change policy, common commercial policy, economic growth, green economy, international trade, investment, sustainable development, trade agreement (EU), trade relations

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.12.2025  SWD(2025) 433 final  COMMISSION STAFF WORKING DOCUMENT  EVALUATION  of the impact of EU's agreements on key environmental aspects, including the climate {SWD(2025) 434 final}  
 
 
Table of contents 

Contents 

1. 

INTRODUCTION .................................................................................................................. 3 

Purpose and scope of the evaluation ........................................................................................... 3 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ......................... 6 

2.1 

Description of the intervention and its objectives .......................................................... 6 

2.2 Point(s) of comparison .......................................................................................................... 7 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? ........... 8 

3.1 

3.2 

3.3 

3.4 

3.5 

MEAs ratification and implementation .......................................................................... 8 

Regulatory cooperation .................................................................................................. 8 

Non-regression ............................................................................................................. 11 

Trade in environmental goods and services ................................................................. 11 

Multilateral alliances .................................................................................................... 13 

4. 

EVALUATION FINDINGS (ANALYTICAL PART) ......................................................... 16 

4.1 Effectiveness and impact ..................................................................................................... 16 

Achieving objectives of the environmental provisions .......................................................... 16 

Environmental protection ...................................................................................................... 17 

Implementation and monitoring structures ........................................................................... 18 

Unintended consequences ..................................................................................................... 19 

4.2 Efficiency ............................................................................................................................ 19 

4.3 Coherence ............................................................................................................................ 20 

4.4 Relevance ............................................................................................................................ 21 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ................................... 22 

5.1 Conclusions ......................................................................................................................... 22 

5.2 Lessons learned ................................................................................................................... 22 

ANNEX I:   PROCEDURAL INFORMATION ............................................................................. 25 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED ..................................... 26 

ANNEX  III.  SUMMARY  OF  BASELINES  FOR  EACH  COUNTRY  ACCORDING  TO 
RELEVANT EVALUATION CRITERIA ........................................................................... 29 
ANNEX IV. MEA RATIFICATION AND IMPLEMENTATION ............................................... 33 
ANNEX V. TRADE IN GOODS ................................................................................................... 38 

ANNEX VI. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS 
TO THE EVALUATION QUESTIONS (BY CRITERION) ............................................... 44 
ANNEX VII. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ............................. 50 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

CBAM 

CBD 

CETA 

CITES 

COP 

DAG 

DCFTA 

DSM 

EPA 

ETS 

EUD 

EUDR 

EUSFTA 

EVFTA 

FAST 

FTA 

GACERE 

EGS 

ESG 

Carbon Border Adjustment Mechanism 

Convention on Biological Diversity 

Comprehensive Economic and Trade Agreement 

Convention on International Trade in Endangered 
Species of Wild Fauna and Flora 

Conference of the Parties 

Domestic Advisory Group 

Deep and Comprehensive Free Trade Area 

Dispute Settlement Mechanism 

Economic Partnership Agreement 

Emissions Trading System  

European Union Delegation 

European Union Deforestation Regulation  

European Union-Singapore Free Trade Agreement 

European Union–Viet Nam Free Trade Agreement 

Friends of Advancing Sustainable Trade 

Free Trade Agreement 

Global Alliance on Circular Economy and Resource 
Efficiency 

Environmental Goods and Services 

Environmental, Social, Governance 

KM-GBF 

Kunming-Montreal Global Biodiversity Framework 

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MEA 

NDC 

PCA 

SPA 

SPS 

TBT 

SEP 

Multilateral environmental agreement 

Nationally Determined Contribution under the Paris 
Agreement 

Partnership and Cooperation Agreement 

Strategic Partnership Agreement 

Sanitary and phytosanitary measures 

Technical barrier to trade 

Single Entry Point 

TESSD 

VPA-FLEGT 

Trade and Environmental Sustainability Structured 
Discussions 

Voluntary Partnership Agreement on Forestry Law 
Enforcement, Governance and Trade 

WTO 

World Trade Organization 

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1. 

INTRODUCTION 

Purpose and scope of the evaluation 

Trade agreements1 signed by the European Union include dedicated provisions on Trade 
and Sustainable Development (TSD). Since the incorporation of the EU’s first TSD chapter 
in  the  Free  Trade  Agreement  (FTA)  with  the  Republic  of  Korea2,  in  2011,  these 
commitments are covering labour, environmental and climate issues, as well as responsible 
business conduct and gender equality.  

In its 2021 Trade Policy Review3 the European Commission recalled the importance of 
ensuring a sound basis for trade policy development, namely by deepening its analytical 
and data collection efforts. Concretely, the Commission announced that it would carry out 
an ex-post evaluation of the impact of the EU’s agreements on key environmental aspects, 
including the climate. In 2022, in its dedicated TSD Communication4, the Commission set 
out  how  to  further  enhance  the  contribution  of  trade  agreements  to  sustainable 
development. 

Subsequently,  in 2023, the European Commission’s Directorate-General  for Trade (DG 
Trade) awarded a contract to a consortium led by Ecorys to undertake an ex-post qualitative 
evaluation  (hereinafter  referred  to  as  “the  evaluation”)  of  the  impact  of  the  EU’s 
agreements on key environmental aspects, including climate. The evaluation was carried 
out from October 2023 to November 2024.  

The  evaluation  assessed  those  trade  agreements  containing  comprehensive  Trade  and 
Sustainable Development (TSD) chapters. At the time the study was commissioned, eleven 
such agreements – applying to trade with 19 partner countries – had been concluded and 
ratified by the EU.5 The evaluation focused on a sample of eight countries (covered by 
seven agreements): Canada, Costa Rica and Honduras (same agreement), Georgia, Japan, 
Peru, Singapore, and Viet Nam.6 

The  contractor  selected  those  trade  partner  countries  and  agreements  to  ensure  that  the 
analysis  was  representative  of  diversity  in  countries’  geography  and  economic 
development as well as with respect to agreements’ length of implementation and evolving 

1 In this report, we refer to trade agreements as “agreements” or “FTAs” for simplicity, even though some 
of them have different names such as “Economic Partnerships” or “Association Agreements”. 
2 Official Journal of the European Union L 127 of 14 May 2011 
3  Trade  Policy  Review  –  An  Open,  Sustainable  and  Assertive  Trade  Policy.  Communication  from  the 
Commission to the European Parliament, the Council, the European Economic and Social Committee and 
the  Committee  of 
the  Regions,  COM(2021)66final,  available  via:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:52021DC0066  
4 The power of trade partnerships: together for green and just economic growth. Communication from the 
Commission to the European Parliament, the Council, the European Economic and Social Committee and 
the  Committee  of  the  Regions,  COM(2022)409final,  available  via:  https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=celex:52022DC0409    
5 While the EU’s agreements with New Zealand and Kenya have subsequently entered into force during the 
study’s implementation, they were excluded from consideration given that their effects could not be assessed. 
6 The EU’s TCA with the UK has been excluded because sustainable development under the TCA is primarily 
an issue of non-regression. The Association Agreement with Ukraine, moreover, has been excluded due to 
the  ongoing  Russian  invasion.  Additionally,  case  studies  were  carried  out  covering  Colombia,  Ecuador, 
Moldova and the Republic of Korea.  

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approaches to TSD by the EU. Specifically, the sample was selected based on the following 
criteria:  

•  Degree  of  similarity  between  the  TSD  chapter  and  relevant  environmental 

provisions in the FTA.7  

•  Representativeness in terms of agreements’ maturity.  
•  Representativeness in terms of income level (classified according to UN and World 
Bank statistical indicators) to generate a sample that included both industrialised 
(OECD)  and  developing  countries  across  different  population  sizes  and  GDP 
levels.  

•  Representativeness in terms of the level of trade between the EU and its partners, 

and in terms of environmental impact areas. 

The  evaluation  generally  started  from  the  initiation  of  trade  negotiations  and  wherever 
possible was carried forward to 2022. In terms of the evaluation parameters, the evaluation 
focused on five key cross-cutting parameters related to the environmental objectives of the 
agreements: (i) ratification and implementation of multilateral environmental agreements 
(MEAs); (ii) promotion of regulatory cooperation; (iii) ensuring that the FTAs did not lead 
to  regression  in  environmental  protection  and  standards  within  partner  countries;  (iv) 
dissemination of environmental goods and services (EGS); and (v) building of multilateral 
alliances  related  to  climate  and  the  environment  between  the  EU  and  partner  countries 
within relevant international fora.  

In  terms  of  environmental  themes,  the  evaluation  focused  on  biodiversity,  circular 
economy, climate, and deforestation. The evaluation also provided 20 case studies, which 
were selected to ensure representativeness across several dimensions (geography, cross-
cutting parameters, environmental themes, FTA maturity, partners' income level and data 
availability).  

Following Better Regulation guidelines, the evaluation assessed the extent to which the 
objectives of EU FTAs’ environmental provisions had been achieved through a series of 
evaluation questions (EQs) based on the four criteria of effectiveness/impact, efficiency, 
coherence and relevance: 

Effectiveness/impact: 

•  EQ1: To what extent have the objectives of the environmental provisions of the 

agreements been achieved? 

•  EQ2: To what extent has the implementation of the environmental provisions of 
the agreements contributed positively to the environment, including climate?  
•  EQ3:  What  are  the  implementing  factors  of  the  agreements  that  are  influencing 
(positively or negatively) the impact on the environment, including the climate? 
•  EQ4:  Has  the  implementation  of  the  agreements  had  unintended  positive  or 
negative  consequences  (including  on  the  economic,  social  and  human  rights 
dimensions) and, if so which ones? 

7  For  instance,  the  agreements  with  Georgia  and  Moldova  have  very  similar  provisions  while  6  Central 
American countries (and 3 countries of the Andean Community) share the same agreement. In light of this, 
the evaluation has selected one country (or, in the case of Central America, two) from each grouping. 

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Efficiency 

•  EQ5:  To  what  extent  are  the  costs  associated  with  the  implementation  of  the 
environmental  provisions  of  the  agreements  proportionate  to  the  benefits  it  has 
generated?  Is  the  distribution  of  both  costs  and  benefits  proportionate  among 
different stakeholders’ groups and interests? 

Coherence 

•  EQ6:  To  what  extent  have  the  implementing  factors  of  the  environmental 
provisions  of  the  agreements  been  coherent  with  EU  trade  and  sustainability 
policies  and  with  the  EU’s  commitment  to  sustainable  development  in  trade 
policies as a contribution to the attainment of the Sustainable Development Goals 
(SDGs)? 

Relevance 

•  EQ7: To what extent do the provisions and implementing factors of the agreements 
continue to be relevant to addressing the current environmental needs and issues? 

Towards  answering  these  questions,  the  contractor  devised  an  evaluation  framework 
setting up the judgement criteria, analytic approach and relevant data sources. Given the 
qualitative nature of the evaluation, the key methodological approach adopted was that of 
contribution analysis, whereby potential outcomes of each agreement were identified on a 
given  cross-cutting  parameter  and  then  assessed  according  to  the  agreement’s  likely 
contribution to that outcome, seeking to exclude alternative factors.  

Key  inputs  for  these  analyses  included  desk  research;8  legal,  policy,  and  regulatory 
analysis; semi-structured interviews and consultations; and trade data analysis.9 In-depth 
analysis was further applied through the 20 case studies, which were designed to illustrate 
and capture impacts at the micro-level by providing empirical evidence of the impact of 
environmental provisions and trade cooperation. 

The contractor noted that the chosen methodology had several limitations related to the 
ascription of causality to the agreements’ environmental provisions on observed outcomes. 
First, because environmental provisions in the EU agreements remain rather broad and not 
prescriptive,  commitments  remain,  at  least  in  part,  subject  to  interpretation.  As  such, 
outcomes  observed  are  often  only  indirectly  linked  to  specific  provisions.  Second, 
environmental priorities and policies adopted in partner countries have generally become 
more ambitious and robust over time and these developments have, in large part, occurred 
independent of their FTAs with the EU.  

8 Sources included existing FTA impact assessments, reports from international organisations, academic 
organisations and think tanks, DAG memoranda and committee declarations and/or statements, as well 
minutes from bilateral and international fora and initiatives. Reference is also made to UNFCCC technical 
reports, REDD+ reports, national biodiversity strategies, and CITES implementation reports, among other 
documentation.  
9 Trade data is sourced from Eurostat and relevant national statistical accounts. In classifying EGS, Chapter 
19 of the EU-New Zealand FTA is used (available at the following link). 

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The final report of the contractor’s evaluation is a source of useful information and trade 
analysis but does not represent the Commission’s views. Sections 2 to 4 present a short 
overview of the contractor’s conclusions; section 5 presents the assessment of Commission 
services of the contractor’s findings and conclusions. Information related to countries are 
presented in alphabetical order of the countries.  

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1   Description of the intervention and its objectives 

The EU-Republic of Korea FTA included the first agreement to include a dedicated TSD 
chapter. Since then, the range of specific environmental topics included in EU agreements 
has increased where the more recent ones include references to climate change, renewable 
energy as well as biodiversity and illegal trade in endangered species. In general, however, 
the  inclusion  of  environmental  provisions  in  EU  trade  agreements  since  2011  (in  the 
chapters  on  TSD  and  elsewhere)  have  aimed  at  promoting  environmental  and  climate 
sustainability through the following objectives: 

•  promoting  ratification  and  more  effective  implementation  of  MEAs  in  partner 

countries;  

•  enhancing  regulatory  cooperation  and  dialogue,  with  the  ultimate  objective  of 
improving  environmental  governance  in  partner  countries  (including  towards 
implementation of MEAs); 
facilitating trade in environmental goods and services (EGS); 

• 
•  building  bilateral  and  multilateral  alliances  in  international  fora  (such  as  at  the 

WTO or COPs to relevant MEAs); and 

•  ensuring that FTAs support environmental standards.  

Towards achieving these goals, all agreements include a range of relevant provisions and 
implementing  factors.  These  include  specific  legal  provisions  calling  for,  inter  alia, 
effective implementation of MEAs, upholding environmental standards, promoting trade 
favouring  sustainable  development  and  cooperating  in  a  range  of  relevant  areas.  They 
further  establish  TSD  Committees  (in  some  agreements  named  “subcommittees”  or 
“boards”)  consisting  of  experts  from  the  EU  and  from  the  partner  countries.  These 
Committees  meet  at  regular 
information  and  facilitate 
implementation of the agreement’s sustainability provisions including on environment and 
climate.  These  exchanges  are  governed  by  transparency  provisions  requiring  parties  to 
notify  the  others  of  relevant  developments  in  environmental  policies  and  practices 
(including toward meeting commitments under MEAs) and also serve as a forum to engage 
in  regulatory  cooperation.  These  agreements  also  provide  mechanisms  for  transparency 
and involvement of civil society through the establishment of Domestic Advisory Groups 
(DAG) and regular civil society dialogues.  

to  exchange 

intervals 

The extent to which these objectives have been attained is assessed in Section 4. Broadly, 
however, the expectation has been that the inclusion of these provisions and implementing 
factors within EU FTAs would serve to enhance the climate and environmental benefits of 

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trade  (e.g.,  through  diffusion  of  EGS  and  improved  regulation),  whilst  mitigating  its 
potential adverse effects. 

2.2 Point(s) of comparison  

The baselines (ranging from pre-2013 to pre-2020) for each of the 8 countries analysed in 
the  sample,  across  the  key  evaluation  parameters  of  MEA  ratification  and  compliance, 
regulatory cooperation and trade in EGS is detailed in the tables in Annex III. 

. 

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3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD? 

3.1  MEAs ratification and implementation 

EU  trade  agreements  affirm  the  parties’  commitments  to  ratify  certain  MEAs  and 
effectively implement the MEAs to which they are signatories. The ex-post analysis looked 
at the impact of EU trade agreements on partner countries' ratification of and compliance 
with MEAs, with a focus in particular on the UNFCCC and Paris Agreement, CITES, and 
the  Convention  on  Biological  Diversity  (CBD)  and  the  Kunming-Montreal  Global 
Biodiversity Framework (KM-GBF). The analysis showed that the EU’s partner countries 
had already ratified the key MEAs by the time the trade agreements entered into force. The 
exception was Peru’s accession to the Paris Agreement and the KM-GBF, which happened 
after the FTA was signed. Looking at the implementation of the agreements, the analysis 
showed a mixed picture between countries. Canada has actively addressed issues linked to 
the Paris Agreement, CITES and the CBD even before CETA was signed, while in some 
other  countries  compliance  was  less  strong,  among  other  due  to  lack  of  resources,  in 
particular  in  developing  countries.  For  a  detailed  analysis  of  the  ratification  and 
implementation of agreements in each of the 8 countries, see Annex IV.   

3.2  Regulatory cooperation 

All  of  the  analysed  trade  agreements  include  calls  for  regulatory  cooperation  on 
environmental issues. While the specific scope of cooperation may vary to some extent 
across  agreements,  they  commonly  include  provisions  calling  for  cooperation  on 
ratification  and  implementation  of  MEAs,  technical  exchanges  and  sharing  of  best 
practices. In addition, CETA includes an overarching chapter on regulatory cooperation 
(Chapter  21).  Annex  I  of  the  contractor’s  evaluation  provides  more  detail  on  these 
provisions. Towards achieving cooperation goals, all agreements establish committees on 
TSD  which  engage  in  regular  dialogues  as  well  as  dedicated  contact  points  in  each 
administration to facilitate ad hoc exchanges. All agreements similarly establish DAGs and 
civil society dialogues to, inter alia, promote engagement with civil society on regulatory 
matters.  

The evaluation provides a number of findings with regard to the current state of play in 
regulatory cooperation. 

The  first  finding  is  that  EU  FTAs  promote  four  forms  of  climate  and  environmental 
regulatory  cooperation  between  the  EU  and  partner  countries:  (i)  notifications  on 
legislative  and  regulatory  developments  in  climate  and  environmental  governance  and 
implementation  of  MEAs;  (ii)  technical  discussions  supporting  regulatory  design  and 
implementation; (iii) discussions on priority areas of future regulatory cooperation;  and 
(iv) exchanges of views and positions in advance of meetings in international fora. 

Notifications  on 
in  climate  and 
legislative  and  regulatory  developments 
environmental governance and implementation of MEAs are the most consistent and 
common form of regulatory cooperation promoted by the EU’s FTAs. They occur during 
each TSD Committee meeting for all agreements and countries and represent a significant 

8 

 
 
 
share of the dialogue that takes place during these exchanges. In the case of FTAs with 
developing countries, these notifications allow the EU to monitor compliance with TSD 
provisions and commitments under MEAs; determine where further action is needed by 
the  partner  country;  and  identify  potential  areas  where  EU  technical  support  can  be 
provided to assist regulatory design and implementation. In the case of more economically 
developed countries, these exchanges facilitate mutual learning on respective approaches 
to  environmental and climate governance and, in  some instances, prompt exchanges on 
best practices and experiences related to policy design and implementation.  

These notifications have similarly provided the EU with an opportunity to provide detailed 
information  to  partner  countries  on  the  significant  developments  occurring  in  the  EU’s 
climate  and  environmental  regulations  (e.g.,  CBAM,  EUDR,  Farm-to-Fork  Strategy). 
These exchanges have allowed partners to ask questions and raise concerns while allowing 
the two sides, where relevant, to discuss potential areas of EU support towards improving 
compliance. During the early stages of regulatory design, partners’ inputs gathered during 
the TSD Committee meetings or facilitated through designated contact points established 
under the TSD chapter have been used to inform the trade-related aspects of these policies.  

Technical  support  on  regulatory  design  and  implementation  are  another  type  of 
cooperation.  The  evaluation  found  out  that  the  FTAs  have  promoted  regulatory 
cooperation  in  the  form  of  technical  support  for  regulatory  design  and  implementation. 
This  cannot  easily  be  discerned  through  the  available  minutes  of  TSD  Committee 
meetings. One of the challenges is that this form of cooperation will generally be carried 
out more intensively through ad hoc exchanges  and meetings that take place outside of 
TSD  Committee  meetings;  making  it  difficult  to  identify  the  extent  to  which  this  has 
occurred and the role of the FTA specifically.  

Among developing partners, technical discussions that do take place are generally oriented 
towards  supporting  the  partner  country  in  legislative  and  regulatory  design  and 
implementation.  Work  plans  for  the  TSD  Committee  for  the  EU-Georgia  Association 
Agreement,  for  example,  demonstrate  that  such  cooperation  can  be  significant  and  has 
included, inter alia, technical support towards the development of Georgia’s forest code, 
updating  of  its  NDC  under  the  Paris  Agreement,  adoption  of  its  Long-Term  Low-
Emissions Development and development of the 2030 Climate Change Strategy and 2021-
23 Action Plan. 

Another example is Viet Nam. While the EVFTA does not contain specific commitments 
on  marine  plastic  litter,  both  marine  plastic  waste  and  the  circular  economy  have  been 
central  to  discussions  in  the  annual  TSD  Committee  meetings.  These  meetings  have 
facilitated exchanges between the EU and Viet Nam on policy frameworks, particularly on 
plastics  pollution  and  EPR  systems,  with  Viet  Nam  demonstrating  strong  interest  in 
learning from EU practices. Recent regulatory initiatives in Viet Nam in this area include 
the launch of the National Plastic Action Partnership (NPAP) ; the adoption of the 2020 
Law on Environmental Protection (LEP), which introduced producer and importer liability 
for recycling and waste treatment, with the updated LEP of January 2022 incorporating 
extended producer responsibility (EPR) provisions—making Viet Nam the first Southeast 
Asian country to enact such a law and laying the foundation for a circular economy.  

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In the case of developed countries, such cooperation primarily consists of the exchange of 
experiences pursuant to key technical aspects related to implementation. Minutes from the 
TSD Committee meetings under the EU-Japan EPA, moreover, demonstrate that this may 
include early-stage discussions on regulatory approaches for nascent issues or emerging 
technologies  (e.g.,  green  hydrogen,  bioplastics)  as  well  as  possibilities  for  regulatory 
approximation between the partners.  

Discussions  on  priority  areas  for  future  cooperation,  are  typically  found  in  TSD 
Committee  meetings,  with  such  exchanges  being  more  relevant  to  developing  partner 
countries that qualify for EU development assistance. While these are viewed as relevant 
to  promoting  regulatory  cooperation,  the  evaluation  could  not  clearly  determine  what 
impact these discussions had on the activities that ultimately take place. 

Nevertheless,  the  analyses  for  FTA  partners  qualifying  for  country-specific  EU 
development assistance (i.e., Honduras, Georgia, Peru, Viet Nam) have demonstrated that 
a number of EU-funded and Team Europe initiatives related to environmental TSD have 
taken  place  explicitly  in  support  of  the  implementation  of  the  relevant  commitments 
included in the FTA.  

Exchange of views and positions in advance of meetings in international  fora is the 
fourth and final type of cooperation activity that was identified. The TSD Committee also 
promotes  cooperation  in  international  fora,  with  meetings  commonly  used  to  exchange 
positions ahead of important multilateral conferences and fora on environmental policy. 
While this is common to all agreements, it is more emphasised in discussions with more 
economically  developed  partners.  For  all  countries,  however,  the  meetings  are  used  to 
build international support for EU’s positions and proposals in international fora.  

The  second  finding  is  that  the  FTAs  and  cooperation  promoted  through  the  TSD  (and 
supported  by  projects  funded  by  the  EU  and  Member  States)  make  it  more  likely  that 
partner  countries  will  be  able  and  willing  to  comply  with  requirements  under  newly 
launched pieces of legislation such as the EUDR.  

All  else  equal,  countries  with  FTAs  with  the  EU  appear  more  likely  to  successfully 
understand the requirements of new regulations emerging from the European Green Deal, 
than countries that do not have an FTA. This is due primarily to two factors: (i) stronger 
engagement with partner countries on these regulations in the form of technical discussions 
and  notifications  and  (ii)  increased  familiarity  and  reliance  on  the  EU  market  among 
producers and exporters in applicable sectors. While the ultimate impact of these measures 
remains to be seen, the EU’s FTAs and cooperation through TSD Committees therefore 
make  it  more  likely  that  the  international  dimension  of  these  EU  initiatives  will  be 
successful and lead to better understanding of the EU requirements in partner countries. 
The  extent  to  which  this  occurs,  however,  will  also  rely  on  continued  and  concerted 
technical support and capacity building, in particular for developing countries. 

The  third  finding  is  that  TSD  Committees  are  often  used  to  engage  in  regulatory 
cooperation on areas outside the FTA and its chapter on TSD. Several interviewees have 
emphasised the importance of the TSD Committee in providing a forum for dialogue (with 
several even asserting that it is the most important outcome arising from the TSD chapters). 

10 

 
 
Alternative opportunities for dialogue may not otherwise exist, thus participants use these 
meetings to discuss areas that might not strictly fall within the TSD chapter.  

The fourth finding is that the conclusion of an FTA increases the EU’s attention devoted 
to environmental issues in partner countries – particularly those that could potentially be 
exacerbated  by  increased  trade  with  the  EU  –  which  in  turn  promotes  increased  EU 
engagement in  regulatory cooperation.  The  conclusion of an FTA results in  the partner 
country receiving greater attention from the EU and heightened scrutiny from CSOs. Also, 
more resources flow to implementation through the establishment of the TSD Committee 
and EU-funded projects supporting implementation.  

The fifth and final finding is that the EU’s FTAs not only promote regulatory cooperation 
between the EU and partner countries but also among partner countries within a shared 
region. Several of the countries analysed are part of regional FTAs (Costa Rica, Honduras 
and Peru) and the analysis suggests that these have promoted environmental and climate 
regulatory cooperation and harmonisation among regional partners. The EU’s Association 
Agreement with Central America, for example, promoted a collective minimum consensus 
and  ensured  that  uniform  environmental  commitments  were  adopted  among  all  Central 
American countries. This has, in turn, led to upgrades in standards and harmonisation of 
environmental  policies  for  all  countries  in  the  region  and  fostered  a  more  cohesive 
approach towards shared goals and objectives. Similar dynamics have been promoted in 
the Andean Community through the EU’s FTA with Colombia, Ecuador and Peru.  

3.3  Non-regression 

All of the EU FTAs with chapters on TSD include clauses on non-regression. While there 
are  minor  variations  in  the  text  of  these  clauses  across  agreements,  they  all  commonly 
stipulate  that  the  Parties  to  the  agreement  shall  not  encourage  trade  or  investment  by 
weakening or reducing the levels of protection afforded in their environmental laws.  

The analysis of the 8 partner countries has not identified any notable instances of regression 
in  environmental  standards  since  the  ratification  of  each  country’s  FTA  with  the  EU. 
Indeed, the overall findings strongly suggest that EU FTAs that include TSD Chapters and 
non-regression clauses have coincided with improvements in environmental standards in 
partner  countries  rather  than  deterioration.  As  such,  the  analysis  finds  no  evidence  that 
EU’s  FTAs  promote  a  race  to  the  bottom  in  environmental  standards  across  partner 
countries, rather the contrary. 

3.4  Trade in environmental goods and services 

Trade in environmental goods 

The contractor provided an overview of developments in trade in environmental goods, for 
trade  between  the  EU  and  each  examined  partner  country.  Detailed  tables  on  the 
developments of imports and exports of environmental goods for each partner country can 
be found in Annex V.  

11 

 
 
 
Defining  and classifying environmental  goods  remain  complex due to  the vast  array of 
products  and  the  rigidity  of  international  trade  classifications.  In  their  analysis,  the 
contractor  adopted  the  taxonomy  used  in  the  EU-New  Zealand  Agreement10.  The 
development of trade in environmental goods is juxtaposed with total extra-EU trade and 
total goods trade excluding environmental goods, both before and after the ratification of 
an EU FTA11.  

The  analysis  shows  that  overall,  the  EU’s  trade  in  environmental  goods  post-FTA  has 
consistently grown, aligning with the overarching aim of more sustainable development. 
Specific  sectors,  particularly  renewable  energy  components  like  solar  and  wind 
technologies,  have  experienced  considerable  growth,  reflecting  global  moves  towards 
sustainability. The overall share of environmental goods in total trade remains  however 
relatively modest. Countries such as Japan, Canada, and Costa Rica have increased their 
focus on energy efficiency and building technologies, showing sectoral improvements. The 
EU continues to exhibit strong trade surpluses in EG with several FTA partner countries, 
demonstrating its competitive edge in exporting green technologies.  

Trade in environmental services 

The contractor also examined changes in the average annual trade flows of environmental 
services12 between the EU and its FTA partners, and the evolution of the commitments 
taken in the FTAs compared to GATS.    

Regarding the changes in the average annual trade flows, the contractor highlighted first 
several limitations inherent to trade in services statistics, and related to the impact of the 
COVID 19 pandemics on trade. The contractor then reviewed trade flows for a limited set 
of  services  that  include  core,  indispensable,  and  other  environmental  services  over  two 
distinct periods:  five years before the ratification of each  FTA and the  respective years 
following their ratification13.  

Overall, while general services trade with the covered economies has been increasing and 
most  of  the  selected  environmental  services  showed  positive  developments  both  for 
imports and exports, some environmental services did not follow this trend. For instance, 
total  services  exports  from  the  EU  to  Canada  grew  by  55%  between  2017  and  2022 
reaching EUR 26 439 million, with technical, trade-related, and other business services 
increasing by 83% and amounting to EUR 2 954 million in 2022. Construction services 
saw significant growth with a 64% rise to EUR 162 million, and waste treatment and de-
pollution services exports surged by 400% to EUR 5 million, but for instance maintenance 

10 Annex 19, see Official Journal L, 2024/866, 25 March 2024 
11 The list of environmental goods is based on Annex 19 of the EU-NZ FTA, which can be aggregated in 
three categories: goods related to energy efficiency, goods related to geothermal, hydro, solar, and wind 
energy,  and  goods  related  to  buildings.  See  Annex  III  of  the  draft  final  report  ’Impact  of  the  EU’s 
agreements  on  key  environmental  aspects,  including  the  climate’,  for  more  details  on  methodology: 
https://policy.trade.ec.europa.eu/analysis-and-assessment/ex-post-evaluations_en 
estimates 
provided  are  based  on  5-year  averages,  which  were  used  in  the  evaluation  to  address  data  gaps  and 
smooth out fluctuations. For the EU-Viet Nam FTA, which was implemented in 2020, 4-year averages 
were calculated for the post-FTA period. 

All 

12 categorised on p. 95 of the Final Report 
13  The  reviewed  services  include  sectors  such  as  waste  treatment  and  depollution  services,  repair  and 

maintenance services, technical, trade-related, and other business services. 

12 

 
 
 
and  repair  services  dropped  by  21%,  down  to  EUR  769  million.  Total  services  exports 
from  the  EU  to  Japan  experienced  a  strong  overall  growth  of  19%,  from  2019  to  2022 
rising to EUR 37 212 million, with maintenance and repair services increasing by 32% to 
reach EUR 691 million. However, exports of technical and trade-related services fell by 
47%  to  EUR  2  169  million.  An  additional  correlation  analysis  showed  (i)  positive 
correlation between trade in the selected environmental services and total trade in services, 
thereby potentially indicating a broader positive trend between growth in trade in services 
and growth in environmental services;  and (ii) positive linkages between exports in the 
selected environmental services and exports of green technologies, thereby identifying a 
possible complementarity between the exports of environmental goods and services.  

Regarding the evolution of the commitments taken in the FTAs compared to the GATS, 
the contractor showcased how FTAs push the level of regulatory security further compared 
to  the  GATS,  providing  a  more  liberalised  and  predictable  environment  for  service 
suppliers,  including  environmental  services  suppliers.  They  illustrated  this  with  several 
examples  for  each  of  the  covered  partner  country.  For  instance,  in  CETA,  Canada 
improved its commitments for the supply of engineering services through Mode 1 and 3, 
dropping  residency requirements in  some provinces/territories.  In its FTA with  the EU, 
Singapore, who has not taken GATS commitment for core environmental services, decided 
to  partially  commit  sectors  such  as  refuse  collection  and  disposal  services,  waste 
management services, nature and landscape protection services.  

3.5 Multilateral alliances 

The  following  section  provides  the  contractor’s  assessment  of  the  role  of  EU  FTAs  in 
fostering multilateral alliances with partner nations, particularly within multilateral fora. It 
provides an overview of the evolution of the EU’s multilateral alliance activities. These 
alliances, often tacit and ad hoc, centre on collaborative efforts to address environmental 
challenges,  including  biodiversity,  climate,  circular  economy,  and  deforestation.  While 
direct linkages between FTAs and such alliances are complex, various mechanisms within 
the EU FTAs mentioned below have been identified that contribute to collaboration; these 
include  incorporating  robust  environmental  clauses,  promoting  sustainable  practices, 
aligning policies, capacity building, and technology transfer. 

Canada and the Comprehensive Economic and Trade Agreement (CETA) 

The  EU  and  Canada  have  a  long  history  of  collaboration  on  environmental  and  trade 
matters.  Even  before  CETA,  both  partners  actively  contributed  to  WTO  environmental 
negotiations and initiatives such as the Friends of Advancing Sustainable Trade (FAST) 
Group and the Trade and Environmental Sustainability Structured Discussions (TESSD). 
Their cooperation has resulted in significant multilateral initiatives, including the Global 
Alliance on Circular Economy and Resource Efficiency (GACERE). 

CETA includes a dedicated chapter on TSD, which promotes environmental cooperation. 
Following CETA’s entry into force in 2017, Canada and the EU hosted clean tech summits 
and engaged in collaborative discussions on sustainability. The two partners have also co-
hosted  ministerial  meetings  on  climate  action  with  China  and  actively  participated  in 
COP27 and COP28 discussions, focusing on carbon pricing and emissions reduction. 

13 

 
 
The  EU  and  Canada  established  the  Green  Alliance  in  November  2023  to  enhance 
collaboration  on  climate  action,  ocean  protection,  green  industrial  transformation,  and 
biodiversity conservation. They jointly support the “30 by 2030” initiative under the High 
Ambition Coalition for Nature and People, aiming to protect 30% of global land and water 
resources by 2030. Furthermore, Canada is a co-host of the Ministerial on Climate Action 
(MoCA)  and  a  member  of  the  Climate  Club,  which  promotes  the  decarbonization  of 
industrial production. 

Costa Rica and the EU-Central America Association Agreement 

Costa  Rica  has  been  actively  engaging  in  environmental  protection  and  multilateral 
environmental agreements (MEAs) before entering the EU-Central America Association 
Agreement (EUCA). The country is a global leader in biodiversity conservation and co-
chairs the High Ambition  Coalition (HAC) alongside France, advocating for the 30x30 
biodiversity target. 

In 2022, Costa Rica presented the EUROCLIMA+ Country Action Plan, which outlines 
climate  actions  aligned  with  its  National  Decarbonization  Plan  and  Carbon  Neutral 
Country Programme. Costa Rica also joined the Climate Club in 2023 and co-chairs the 
TESSD discussions at the WTO with Canada, demonstrating its leadership in trade and 
environmental sustainability initiatives. 

Japan and the EU-Japan EPA 

Japan actively collaborates with the EU on climate initiatives. Japan was the first country 
to  sign  a Green Alliance with  the EU in  2021, which promotes regulatory cooperation, 
sustainable  energy  transition,  biodiversity  conservation,  and  low-carbon  technology 
development. The EU and Japan are also key players in the WTO’s TESSD, the Coalition 
of Trade Ministers on Climate, and negotiations on an Environmental Goods Agreement 
(EGA).  Furthermore,  both  partners  work  closely  in  facilitating  offshore  wind  and 
regulatory cooperation in this sector. 

Singapore and the EU-Singapore Free Trade Agreement (FTA) 

Singapore has deepened its environmental cooperation with the EU since signing the FTA. 
In  2020,  under  the  Trade  and  Sustainable  Development  Board,  Singapore  engaged  in 
discussions  with  the  EU  on  global  efforts  to  address  plastic  pollution.  By  2023,  both 
partners had  coordinated their positions  ahead of UN negotiations for a legally binding 
treaty on plastic pollution. 

Singapore  is  a  strong  supporter  of  the  WTO’s  environmental  initiatives,  including  the 
TESSD and EGA negotiations. It is also a member of the Climate Club and a founding 
participant in the Forest & Climate Leaders’ Partnership (FCLP). 

Viet Nam and the EU-Viet Nam Free Trade Agreement (EVFTA) 

Viet Nam’s engagement with the EU in environmental matters has gained momentum in 
recent years. At CITES COP19 in 2022, the EU and Viet Nam co-sponsored amendments 

14 

 
 
 
to  improve the protection of endangered species.  Viet  Nam also  joined the Just Energy 
Transition Partnership (JETP) with the EU and other partners, committing to a net-zero 
emissions target and securing $15.5 billion in financial support for energy transition. 

Viet Nam and the EU also signed a Voluntary Partnership Agreement (VPA) under the 
Forest Law Enforcement, Governance and Trade (FLEGT) framework, aimed at ensuring 
sustainable timber trade. Viet Nam is preparing to implement forest governance and legal 
timber trade regulations for EU exports by 2025. Additionally,  Viet Nam is a founding 
member  of  the  Forest  and  Climate  Leadership  Partnership  (FCLP),  reinforcing  its 
commitment to environmental protection. 

Other relevant initiatives discussed in the evaluation include:  

•  Fossil Fuel Subsidies Reform Initiative (FFSR). The FFSR initiative involves 48 
WTO  members  working  to  address  inefficient  fossil  fuel  subsidies.  Canada  has 
abstained from these discussions due to its economic reliance on fossil fuels, while 
Costa  Rica  is  an  active  participant.  The  initiative  focuses  on  enhancing 
transparency,  reviewing  crisis-related  subsidies,  and  developing  pathways  for 
subsidy  reduction.  The  Friends  of  Fossil  Fuel  Subsidy  Reform  (FFFSR)  is  an 
informal  group  advocating  ambitious  and  transparent  reforms.  Members  include 
Costa  Rica,  Denmark,  Ethiopia,  Finland,  New  Zealand,  Norway,  Sweden, 
Switzerland, and Uruguay. The group collaborates within forums such as the G20, 
OECD, and UNFCCC. 

•  The  Trade  and  Environmental  Sustainability  Structured  Discussions  (TESSD) 
Originally an informal initiative led by Canada, the EU, Costa Rica, Norway, and 
Switzerland in 2019, the FAST Group evolved into the TESSD in 2020 under WTO 
auspices. TESSD now has 78 members, including key EU trade partners. It holds 
discussions on trade-related climate measures, environmental goods and services, 
circular economy, and subsidies. 

•  Dialogue on Plastics Pollution (DPP). Launched at the WTO in 2020, the DPP has 
grown  to  83  members  as  of  February  2025,  including  the  EU  and  Canada.  It 
promotes transparency in plastic trade flows, reductions in harmful plastics, and 
increased trade in sustainable alternatives.  

•  Coalition  of  Trade  Ministers  on  Climate.  Established  in  2022  at  the  World 
Economic Forum, the Coalition focuses on how trade policy can support climate 
action. It fosters cooperation between trade and climate communities and promotes 
sustainable finance. The coalition was actively involved in COP28, which featured 
the first dedicated Trade Day and Trade House at a UN climate conference. 

While the direct impact of EU FTAs on multilateral alliances is complex, trade agreements 
play an indirect role in fostering collaboration. Many alliances are tacit and ad hoc, with 
limited explicit references to environmental partnerships in FTAs. However, the EU and 
its  partners  engage  closely  in  environmental  governance  through  platforms  such  as  the 
UNFCCC,  and  CBD.  Increasingly,  trade  and  environmental  discussions  intersect,  as 
demonstrated by trade days at UNFCCC COP28 and CBD COP16. Private sector and civil 
society engagement further complement these efforts, contributing to stronger multilateral 
cooperation on sustainability. 

15 

 
 
 
4.  EVALUATION FINDINGS (ANALYTICAL PART) 

The  evaluation  findings  are  presented  according  to  the  following  evaluation  criteria: 
effectiveness and impact; efficiency; coherence; and relevance. Annex III of the evaluation 
provides the underlying evaluation matrix.  

4.1 Effectiveness and impact  

Achieving objectives of the environmental provisions  
The  objectives  of  the  agreements’  environmental  provisions  have  been  largely  met. 
Compliance with MEAs varies due to exogenous and endogenous factors that are not 
related  to  the  agreements,  however  the  agreements  contributed  to  raise  the  level  of 
ambition  in  environmental  policy-making.  Regulatory  cooperation  with  partner 
countries  has  intensified  under  the  agreements,  and  new  multilateral  alliances  were 
launched.  In  addition,  trade  in  EGS  grew  faster  than  overall  trade,  albeit  from  a  low 
starting level. Finally—and importantly— the findings strongly suggest that the FTAs 
coincided with improvements in environmental standards in partner countries.  

Many partner countries had already ratified the relevant MEAs before the agreements were 
concluded; all of them signed and ratified the Paris Agreement soon after it was agreed. 
Similarly,  by  the  time  the  agreements  entered  into  force,  all  countries  were  already 
signatories to the CBD and CITES. The sampled countries are complying with these MEAs 
to  varying  degrees.  However,  the  degree  of  compliance  cannot  be  attributed  to  the 
agreements. In some instances, exogenous constraints—such as Singapore’s geography—
play a more important explanatory role. Similarly, while the agreements did contribute to 
raising the level of ambition in environmental policy-making and cooperation with partner 
countries  such  as  Viet  Nam  and  Georgia,  compliance—especially  in  developing 
countries—remains  constrained  by  domestic  gaps  in  governance  and  enforcement 
capabilities.  

In other instances, partner countries tend to have a higher degree of compliance with MEAs 
due  to  endogenous  drivers,  such  as  historically  higher  levels  of  environmental  policy 
ambition—as in the case of Costa Rica—or pre-existing commitments to environmental 
protection as in the case of Canada.  

With regard to  regulatory cooperation,  the evaluation found out  that the  agreements  do 
lead to a higher intensity of cooperation between the EU and partner countries. Cooperation 
ranges from mutual notifications and information-exchange on environmental policy and 
legislation  to  the  exchange  of  positions  ahead  of  international  fora  such  as  the  COP. 
Establishing a direct causal link between the agreements and these activities is challenging, 
however, as cooperation often stems from pre-existing frameworks.  

Indeed, for nearly all countries analysed, the key institutional framework for environmental 
policy cooperation typically falls outside of the FTA – either as a separate agreement (as 
in the case of the EU’s PCA with Viet Nam, PDCA with Peru and SPAs with Canada and 
Japan) or within titles of the agreement separate from the trade part (as in the cases of the 
Association Agreement with Georgia).   

16 

 
 
 
While the Association Agreement with Georgia clearly facilitated regulatory cooperation 
on  climate  policy,  the  DCFTA’s  specific  impact  on  environmental  provisions  is  less 
evident. Discussions on cooperation that occur within the context of the TSD Committees 
appear  to  be  largely  complementary  to  those  that  take  place  through  the  frameworks 
created under these political dialogue and cooperation agreements. 

At  the  same  time,  however,  synergies  between  these  different  institutional  frameworks 
appear  to  exist,  with  the  FTAs  reinforcing  pre-existing  dialogues.  An  example  that  is 
provided  in  the  evaluation  relates  to  the  case  of  Viet  Nam.  Although  Viet  Nam  had 
concluded  its  Partnership  and  Cooperation  Agreement  (PCA)  with  the  EU  prior  to  the 
conclusion  of  the  FTA,  the  regular  high-level  and  sub-committee  meetings  established 
under  the  PCA  did  not  begin  regularly  occurring  until  the  FTA  had  been  ratified.  The 
evaluation noted the increased focus following the FTA ratification, leading to increased 
resources  for  bilateral  dialogues  and  more  effective  application  of  the  opportunities  for 
engagement created by the PCA. 

Similarly,  the  EU  has  been  effective  in  leveraging  the  agreements,  among  other 
mechanisms, for alliance-building. While many multilateral initiatives occurred in parallel, 
there are specific cases in which the agreements contributed to alliances and cooperation 
at the multilateral level. These include the EU providing support to Viet Nam in the context 
of the Global Plastics Agreement; and the successful submission of two joint proposals for 
species listing during the CITES COP19 by the EU and Viet Nam.  

Trade in environmental goods grew faster than overall trade in the eight partner countries 
after FTAs took effect, albeit from a low starting level. This suggests that FTAs contributed 
to  fostering  trade  in  environmental  goods.  FTAs  positively  impacted  environmental 
services trade too, though detailed data is available only for Canada, Japan, and Singapore, 
leading to cautious optimism about similar trends in other countries. Correlation analysis 
also  showed  a  positive  relationship  between  trade  in  environmental  goods  and  trade  in 
environmental services.  

All of the EU FTAs with chapters on TSD include clauses on non-regression, stipulating 
that partner countries shall not encourage trade and investment by lowering environmental 
standards. The findings strongly suggest that the FTAs coincided with improvements in 
environmental standards in partner countries; in contrast, the analysis found no evidence 
of regression in terms of environmental policy in any of the 8 countries.   

Environmental protection  
The  evaluation’s  findings  suggest  that  the  implementation  of  the  agreements’ 
environmental  provisions  has  contributed  to  improved  environmental  protection 
outcomes,  particularly  through  regulatory  cooperation.  Additionally,  EU  agreements 
have  facilitated  the  diffusion  of  environmental  goods  and  services,  thus  providing 
increased  access  to  cutting  edge  technologies  supporting  national  decarbonisation 
policies.  

Assessing  the  extent  to  which  the  implementation  of  the  agreements’  environmental 
provisions has enhanced environmental protection is difficult in methodological terms, as 

17 

 
 
 
ascertaining  causality  is  challenging.  The  evaluation,  however,  has  found  several 
examples,  particularly  with  regard  to  the  role  of  regulatory  cooperation  in  leading  to 
improved  environmental  protection  outcomes.  In  the  case  of  Georgia,  EU-Georgia 
dialogue has contributed to improved commitments under MEAs (notably by contributing 
to the updating of NDCs or development of sectoral NAMAs). 

In  the  case  of  Japan,  the  EPA’s  institutional  framework,  particularly  its  Committee  on 
Regulatory Cooperation, has successfully facilitated discussions on regulatory concerns, 
such as tendering requirements, conformity assessment, and the cabotage regime. This has 
been successful to a large extent as  conformity assessment procedures for fixed-bottom 
offshore  wind projects  were simplified. The cabotage regime has  also  just undergone  a 
minor revision 

Regulatory cooperation between the EU and the government of the Republic of Korea in 
the context of the FTA has had similar outcomes. Prior to 2022, the Republic of Korea 
used  local  content  requirements  (LCRs)  in  the  offshore  wind  industry  to  incentivise 
operators to source at least a 50% share of components locally rather than internationally. 
The EU was successful in engaging in dialogue with the Republic of Korea’s government 
to remove local content requirements for offshore wind turbine projects, with this dialogue 
occurring in both the Trade and the TSD Committees.  

In  the  case  of  Costa  Rica,  EU  financial  and  technical  support  in  the  context  of  the 
Association  Agreement  has  contributed  to  the  development  of  key  policy  documents, 
including  the  country’s  National  Climate  Change  Adaptation  Policy  (2018-2030),  the 
National  Strategic  Plan  2050,  and  the  National  Landscape  Restoration  Strategy  (2021-
2050).  Cooperation  has  also  been  fostered  under  the  EUROCLIMA+  programme.  In 
addition,  discussions  in  the  TSD  Committee  facilitate  the  exchange  of  updates  and 
information on key autonomous measures, including CBAM, the Farm-to-Fork strategy, 
and the EUDR.  

Another example of cooperation and dialogue leading to greater environmental protection 
is Viet Nam’s signing of the VPA FLEGT with the EU in 2019. While negotiations began 
in 2019, the EVFTA seems to have incentivised the country to sign the VPA, encouraging 
civil society participation and improving the sustainability of the timber supply chain.  

The EU’s Agreements also contribute to an increase in the diffusion of EGS both in the 
EU and partner countries. This active engagement in environmental goods trade, largely 
facilitated by tariff liberalisation coupled with the harmonisation of public procurement, 
expands access to cutting-edge technologies. 

Implementation and monitoring structures 
The  evaluation’s  findings  suggest  that  the  TSD  Committees  are  useful  platforms  for 
regulatory  cooperation  and  information  exchange.  The  DAGs  and  Civil  Society 
Dialogues  face  greater  challenges,  particularly  in  ensuring  effective  bilateral 
communication  between  civil  society  and  government  representatives.  Areas  for 
improvement include strengthening the DAGs as sources of information and monitoring; 
encouraging  greater  participation  of  environmental  organisations  in  the  DAGs;  and 

18 

 
 
improving communication and information exchange between the DAGs and the TSD 
Committees.  

The evaluation focussed on three key implementing factors, all facilitating dialogue and 
cooperation  between  different  stakeholders.  The  TSD  Committees  are  government-to-
government fora, which are widely regarded as useful platforms for exchange on technical 
matters.  

DAGs  serve  as  platforms  for  civil  society  engagement  but  face  challenges  in  ensuring 
adequate representation of environmentally-focussed CSOs and less active and informed 
CSOs in partner countries. The COVID-19 pandemic has reportedly led to a decrease in 
the quality of information flow and engagement. Despite these challenges, DAGs remain 
the primary avenue for civil society participation. 

Finally, Civil Society Dialogues are found to be less specific compared to DAGs, but an 
essential  tool to broaden participation, as they can offer a useful platform to raise issues 
and are an independent and diverse source of information. 

Unintended consequences  
The  evaluation  findings  suggest  that  there  is  little  evidence  of  negative  unintended 
consequences.  

Overall, the agreements appear to have supported the efforts of partner countries to adopt 
international environmental standards. This is due to a combination of the greater visibility 
afforded to environmental issues by the agreements; the regular exchanges and cooperation 
mechanisms  established  by  the  agreements;  and  the  interest  in  meeting  sustainability 
standards to access the EU market as is the case in Colombia, for example, where palm oil 
producers  began  to  adapt  their  production  methods  due  to  the  increased  market-driven 
demand for certified sustainable palm oil in the EU.  

The evaluation finds a similar example for the marine plastic waste in Viet Nam. Here, the 
agreement created economic opportunities for Viet Namese businesses that necessitated 
the  adoption  of  specific  standards  and  requirements  related  to,  for  instance,  packaging, 
product standards, and environmental protection regulations related to processes. This has 
had  a  positive  effect  on  resource  efficiency  and  waste  management  in  export-oriented 
industries. 

With  regard  to  other  positive  consequences,  investment  flows  in  green  technologies, 
particularly with Canada and Japan, seem to have increased under the agreements, although 
a direct causal link remains uncertain. 

4.2 Efficiency 

The benefits of environmental provisions in FTAs generally outweigh the costs, with 
increased  dialogue  and  trade  creation  as  key  advantages.  While  implementing 

19 

 
 
 
 
environmental clauses incurs personnel and transaction costs, their marginal cost is low, 
and they facilitate dialogue which might not exist otherwise.  

The costs of implementing the environmental provisions primarily involve personnel and 
transaction costs linked to the TSD Committees and other fora for dialogue, while a key 
benefit is the enhancement of mutual understanding and trust between partners. However, 
since dialogue and cooperation are established by the agreements as a whole, the additional 
costs of the environmental provisions are minimal.  

In addition, the TSD Committees facilitate discussions on compliance for exports of key 
commodities. They also often expand the dialogue with partners beyond the TSD Chapter. 

The cases of offshore wind development in the Republic of Korea and Japan, among other 
instances  of  regulatory  cooperation,  show  that  a  bilateral  agreement  can  contribute  to 
regulatory and business activities that facilitate sustainable development. In this case, an 
increase in EGS trade is not only positive per se, in terms of trade creation; but also because 
it leads to more sustainable energy generation in partner countries. 

Challenges  include  capacity  issues  for  businesses  in  developing  countries,  particularly 
SMEs  struggling  to  meet  higher  environmental  standards.  Compliance  costs,  evolving 
regulations,  and  infrastructure  limitations  pose  burdens;  however,  all  these  challenges 
would exist even without the FTAs environmental provisions. 

4.3 Coherence   

The evaluation findings suggest that the agreement’s delivery mechanisms are coherent 
and synergetic with EU’s commitments, both at the global level and within individual 
partner countries. One area for improvement that was identified is the level of generality 
of  environmental  provisions,  which  limits  the  stakeholders’  ability  to  carry  out 
monitoring.  

The agreement’s delivery mechanisms are coherent with EU sustainable trade objectives. 
They work in synergy with other initiatives and activities including the Green Partnerships 
and Alliances, and are widely considered helpful in attaining the SDGs. Overall, the EU is 
perceived as  a leader in  setting  sustainability  standards and  regulations and influencing 
international norms that can be followed by partners, in areas including carbon emission 
and recycling.  

Within  partner  countries,  these  mechanisms  play  a  key  role  by  providing  an  additional 
platform  through  which  needs  for  technical  assistance  can  be  expressed  and  addressed, 
suggesting that the agreements can lead to fine-tuning technical assistance in areas that are 
relevant for the attainment of the environmental provisions in the agreements. This can, in 
turn,  facilitate  the  exchange  of  best  practices,  promoting  regulatory  convergence  and 
fostering public-private dialogue. 

20 

 
 
 
 
However,  stakeholders  noted  that  that  environmental  provisions  are  often  less  clearly 
defined than labour provisions, limiting the ability of both governments and civil society 
to monitor their progress. 

4.4 Relevance 

The  environmental  provisions  and  implementing  factors  of  the  agreement  remain 
relevant to address current environmental needs. The EU’s own latest developments in 
environmental policy with the introduction of measures including CBAM and the EUDR 
mean  that  these  measures  are  now  becoming  more  prominent  in  dialogues  under  the 
agreements.  

The  environmental  provisions  in  EU  trade  agreements  generally  address  current 
environmental  needs.  However,  their  ongoing  relevance  can  depend  on  the  strength  of 
trade  relationships.  In  Viet  Nam,  where  trade  with  the  EU  is  growing,  the  promise  of 
economic  benefits  encourages  engagement  with  non-trade  issues  like  environmental 
protection. In contrast, Georgia's trade with the EU remains limited, reducing the DCFTA’s 
leverage in driving environmental improvements.  

Keeping environmental clauses up to date remains a priority but also a challenge due to 
rapid  legislative  developments  in  the  EU.  Many  stakeholders  noted  that  environmental 
provisions  in  the  agreements  lack  specificity,  and  they  often  fail  to  outline  clear 
consequences for non-compliance. At the same time, discussions are increasingly shifting 
toward  autonomous  EU  regulatory  measures  like  the  EUDR  and  CBAM,  which  have 
gained prominence in TSD Committee agendas.  

Concerns within the private sector about stricter EU environmental standards highlight the 
need  for  ongoing  dialogue  to  ensure  mutually  beneficial  outcomes.  Strengthening 
enforcement  mechanisms  and  fostering  collaboration  between  governments  and  civil 
society  actors  could  improve  compliance.  The  EU’s  expertise  and  technology  offer 
opportunities  for  partner  countries  to  enhance  product  quality  and  integrate  into  global 
supply chains but achieving this requires greater support from the European Commission 
and the private sector. 

Market  transparency  is  improving  through  measures  like  e-procurement  systems,  but 
restrictive technical specifications and the need for guidance remain challenges. EU trade 
agreements  also  play  a  key  role  in  partner  country  commitments  to  MEAs,  facilitating 
negotiations  and  aligning  commitments  with  national  interests  through  advisory  group 
mechanisms and consultations. 

21 

 
 
 
 
5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

5.1 Conclusions 

In general  terms, the  Commission  services consider that the environmental and  climate 
provisions in EU FTAs contribute positively to the environmental policy and sustainability 
efforts  of  its  trading  partners.  They  help  reinforce  existing  commitments  and,  in  some 
cases, encourage the adoption of additional environmental protocols. They play a limited 
but supportive role in ensuring compliance and enforcement.  

EU  trade  agreements  serve  as  platforms  for  intergovernmental  exchange,  regulatory 
cooperation, and dialogue on climate and environmental policies. The agreements facilitate 
regulatory cooperation through TSD committees, transparency provisions, and economic 
incentives. 

FTAs  also  contribute  to  alliance-building,  supporting  informal  and  multilateral 
cooperation  on  biodiversity,  climate,  circular  economy,  and  deforestation.  While  direct 
connections between the agreements and these alliances are difficult to establish, the FTAs 
provide  mechanisms  for  collaboration,  sustainable  policy  alignment,  and  technology 
transfer. 

Trade in Environmental Goods and Services (EGS) is another area where EU FTAs have 
played a role, supporting the diffusion of green technologies and sustainable production 
methods.  EGS  trade  helps  economies  transition  towards  sustainability  by  promoting 
renewable energy, circular economy models, and eco-friendly technologies.  

Importantly, there is evidence that EU FTAs have led to improvements in environmental 
standards in partner countries. While external factors often shape environmental policies 
more  than  FTAs  themselves,  the  absence  of  a  "race  to  the  bottom"  suggests  that  these 
agreements provide a stable framework for sustainable trade practices. 

The  Commission  services  agree  with  the  evaluation  that  environmental  clauses  in  EU 
FTAs are effective, efficient, coherent, and relevant. They have helped partner countries 
implement MEAs and improve regulatory cooperation, both bilaterally and multilaterally. 
Trade in EGS has increased, albeit from a low starting point, supporting the transition to a 
sustainable economy. Overall, the inclusion of environmental provisions in EU FTAs has 
certainly been a success.  

5.2 Lessons learned 

The evaluation also provided several recommendations to the EU for further improvements 
on process and substance with regards to environmental provisions in FTAs.  

The  Commission  services  take  good  note  of  the  evaluation’s  recommendation  for 
improved  communication  between  the  European  Commission  services  and  the  wider 
public, including civil society groups in both the EU and partner countries. 

The Commission services are taking steps to improve the procedures in the TSD bodies 
(boards,  committees  or  subcommittees  as  the  case  may  be),  including  the  interactions 
between the TSD body and the DAGs and of course with the wider civil society. 

22 

 
 
The  Commission  services  are  implementing  the  various  action  points  of  the  2022  TSD 
Communication, including reinforcing the role of the civil society. Starting with supporting 
DAGs logistically, financially and with expertise, a new contract with a service provider 
was signed at the end of 2024. The contractor can organise meetings of the DAGs, provide 
secretarial support to meetings of civil society in relation to the trade agreements, provide 
capacity building to increase the participation of EU and partner countries civil society and 
support communication on the work of the DAGs. 

In line with the 2022 TSD Communication, the Commission is also working on upgrading 
the institutional set-up for the DAGs in the framework of the existing trade agreements. So 
far, the Republic of Korea and Viet Nam have agreed to strengthening the relevant DAGs. 
Dialogues with the remaining partners are ongoing. 

Furthermore, in agreement with the partner countries, the Commission is inviting DAG co-
chairs  to  participate  in  part  of  the  discussions  of  the  TSD  bodies  and  rescheduling  the 
sequence of the meetings to allow for better taking into account the positions and advice 
coming from the DAGs. 

It should be noted that the Commission cannot undertake that unilaterally; the consent of 
the  other  party  to  the  agreements  is  necessary,  and  the  level  of  openness  towards  the 
advisory role of civil society varies across partners. 

In particular, as regards DAGs composition, the various agreement stipulate that DAGs 
should  comprise  a  balanced  representation  of  independent  civil  society  organisations, 
including  non-governmental  organisations,  trade  unions,  and  business  and  employers’ 
organisations. However, it is the prerogative of each party to establish its own appointment 
rules under the abovementioned parameters, and interference in this process is a sensitive 
issue. 

To  present  various  topics  of  interest  to  the  civil  society,  the  Commission  organises 
regularly  Civil  Society  Dialogues.  For  instance,  two  Civil  Society  Dialogues  have 
discussed the present evaluation and supported the study.  

In several  instances,  the  evaluation  referred to  the  way the Commission  introduces and 
presents EU autonomous measures under the European Green Deal (e.g. EUDR, CBAM). 
Such environmental measures are unrelated to the insertion of TSD clauses in the EU trade 
agreements,  since  the  commitment  is  for  both  parties  to  uphold  international  standards 
under  multilateral  environmental  agreements.  However,  as  noted  in  the  evaluation,  the 
institutional framework of the agreements and in particular the meetings of the TSD bodies 
have played an important role in presenting and explaining the relevant EU policies and 
assuaging our partners’ concerns. 

The  evaluation  makes  a  few  recommendations  concerning  the  EGS,  to  which  the 
Commission services respond as follows: 

As regards the need to refine the classification of EGS in collaboration with international 
organisations such as the WTO and the OECD, the Commission will continue to participate 
in discussions in this regard in relevant fora. 

23 

 
 
As  regards  the  suggestion  to  increase  the  availability  of  comprehensive  trade  and 
investment  data  on  EGS,  the  Commission  will  continue  to  engage  with  relevant 
stakeholders and organisations (e.g., OECD, Eurostat) to further develop bodies of data 
and evidence on Environmental Services to inform policy making in this domain;  

As regards the recommendation to strengthen regulatory environments in partner countries 
and facilitate investment in environmental services by removing barriers such as foreign 
equity  restrictions  and  licensing  requirements  that  hinder  EU  service  providers,  the 
Commission services will continue to negotiate ambitious disciplines on trade in services, 
including  environmental  services,  in  ongoing  and  future  negotiations,  thereby  ensuring 
more transparent and predictable regulatory framework for EU businesses. 

The evaluation advises also to prioritise international cooperation in standard-setting and 
to encourage reciprocal recognition of standards and certifications between the EU and its 
trading partners to reduce non-tariff barriers such as technical barriers to trade. It is noted 
that this area is covered by other chapters of the FTAs such as trade in goods and TBT / 
SPS issues. It is not specifically linked to the environmental aspects of the TSD chapters, 
the disciplines of which are anchored in multilateral environmental agreements. 

The  evaluation  also  makes  some  recommendations  on  issues  beyond  the  scope  of  the 
impact  of  FTAs  on  key  environmental  aspects  including  climate,  for  example  on 
international standards and on public procurement, which – while duly noted – will not be 
discussed in this Staff Working Paper. 

Finally, the Commission Services take good note of the evaluation and its findings, and 
will  use  it  to  inform  future  work  and  developments.  There  will  be  continued  focus  on 
monitoring and the correct implementation of the environmental and climate provisions of 
Free Trade Agreements.   

24 

 
 
 
ANNEX I:   PROCEDURAL INFORMATION 

Lead DG: European Commission Directorate-General for Trade, DG Trade 

Decide reference number: SI2.902643 – TRADE/2023/OP/0010 – Ex-post evaluation of the impact 
of the EU’s agreements on key environmental aspects, including the climate 

Organisation and timing: An Inter-service Steering Group (ISG) was established in October 2023 
for the purpose of overseeing the implementation of the project. 

Evidence, sources, and quality: The evidence for the evaluation was gathered through various 
activities and the following sources: 

•  A series of semi-structured, in-depth interviews with individual (or, in some instances, 
small  groups  of)  stakeholders  –  these  are  described  and  summarised  in  Annex  IV 
below;  

•  Stakeholder inputs and responses to a survey directed at private sector and civil society 

stakeholders (see Annex IV for the details);  

•  February  2025.  External  Contractors’  Final  Report  –  Main  Report  of  the  Ex-post 
evaluation of the impact of the EU’s trade agreements on the environment, including 
the climate 

25 

 
 
 
 
ANNEX II. METHODOLOGY AND ANALYTICAL MODELS USED 

The evaluation followed the methodology laid out in the 2024 inception report for the ex-post 
evaluation, which followed and was guided by the Better Regulation Toolbox. The evaluation 
focuses  on  the  effectiveness  and  impact;  efficiency;  coherence;  and  relevance  of  the  EU 
Agreement’s environmental provisions and their implementing  factors on the environment, 
including the climate. Annex III below provides the full evaluation matrix for the evaluation.  

The evaluation assessed the following questions: 

•  The degree to which the objectives of the Agreements’ environmental provisions have 

been achieved; 

•  The  extent  to  which  the  environmental  provisions  have  contributed  (positively  or 

negatively) to the environment;  

•  The  extent  to  which  the  implementing  factors  of  the  Agreements  contributed  to 

environmental protection; and  

•  The extent to  which the  environmental provisions are  coherent  with  EU  and global 

sustainability priorities; and the extent to which they remain relevant. 

To  address  these  questions,  the  evaluation  is  based  on  a  set  of  distinct  sources  and  inputs. 
These are as follows: 

•  Previous studies of the Agreements, especially the Sustainability Impact Assessments 

that were carried out. These are summarised in the Inception Report.  

•  An evaluation study commissioned to an external contractor served as an important 
input into the evaluation. The external study used primarily qualitative methods  but 
also  quantitative  methods  (for  the  study  of  trade  in  EGS),  and  it  also  relied  on  an 
extensive review of the academic and grey literature; as well as on an in-depth legal 
analysis of the environmental provisions in the EU FTAs (reported in Annex I of the 
external evaluation study). It included twenty case studies and it relied on extensive 
consultations  with  stakeholders.  The  external  study’s  findings,  conclusions,  and 
recommendations were discussed with and within the Commission services.  

•  Statistical data from EU sources, notably Eurostat. This is primarily data on bilateral 
trade in EGS, complemented by other sources such as UN COMTRADE for global 
trade.  

•  Consultations  were  used  to  collect  qualitative  data  and  view  from  a  wide  range  of 

stakeholders.  

In terms of methodology, in a first stage, an intervention logic was designed as to make the 
links between the environmental provisions and the outcomes under study  explicit. On this 
basis, the evaluation matrix was designed.  

For each evaluation question and judgment criteria, a similar methodological approach was 
applied. This followed the methodology of contribution analysis, whereby potential outcomes 
of  each  agreement  are  identified  on  a  given  cross-cutting  parameter  and  then  assessed 
according  to  the  agreement’s  likely  contribution  to  that  outcome,  seeking  to  exclude 
alternative factors. 

26 

 
This  framework  was  chosen  due  to  several  considerations.  The  first  is  that  the  content  of 
environmental provisions and TSD Chapters remains rather broad and not prescriptive. Since 
commitments  remain,  at  least  in  part,  subject  to  interpretation,  the  outcomes  that  can  be 
observed are often only indirectly linked to specific provisions.  This stands in contrast with 
provisions on labour rights, which are more prescriptive and therefore easier to monitor and 
enforce.  

Secondly, it is apparent that many countries inside and outside of the EU have developed their 
own environmental priorities alongside the EU. Increasing awareness of climate change and 
environmental  issues  (and  their  wider  impact  on  human  health  and  even  economic 
opportunities and performance) has meant that countries have made environmental protection 
and climate action a policy priority. This is particularly the case for industrialised economies 
and like-minded partners, which tend to have both the ambition to upgrade their environmental 
policies and the means to pursue them. 

In  addition,  in  those  countries  which  may  not  have  the  means  or  governance  structures  to 
pursue effective environmental policies—particularly when it comes to implementation on the 
ground—EU  FTAs  are  only  one  of  the  available  policy  instruments.    Environmental 
provisions act in tandem with other activities carried out by the European Commission and 
EU  Member  States,  including  technical  assistance  and  other  agreements  and  cooperation 
frameworks, such as frameworks supporting a possible accession candidacy, as in the case of 
Georgia.  Political  will  is  another  important  variable.  There  may  be  partners  whose 
environmental policy priorities and ambitions do not fully align with the EU's priorities. They 
may  give  higher  priority  to  other  objectives,  e.g.  escaping  poverty.  In  these  cases,  partner 
countries may not feel ready to fully comply with the environmental provisions in an FTA. 

All these considerations mean that the evaluation could only focus on the contribution of the 
environmental  provisions  to  certain  outcomes;  these  cannot  be  attributed  solely  to  the 
provisions. Taken together, this feature of the methodology as well as the primarily qualitative 
nature of the evaluation give rise to an important limitation of the study, namely that the direct 
causal link between the environmental provisions or the implementing factors on the one hand; 
and the outcomes on the other cannot be proven in a definitive manner. 

While  the  analysis  of  trade  in  EGS  followed  the  same  approach,  it  was  supported  by 
descriptive and statistical analysis of data in trade flows for both goods and services using the 
list of EGS that is specified in Chapter 19 of the EU-New Zealand Agreement as the basis for 
the analysis. The data analysis includes, among other elements, before and after comparisons 
in trade flows for both goods and services, as well as correlation analysis of international EU 
services trade.  

Despite the limitations inherent in the qualitative nature of the evaluation, the quality of factual 
information  and  evaluation  findings  presented  in  the  evaluation  report  has  been  assured 
through  an  internal  and  external  review  process  undertaken  primarily  at  the  level  of  the 
external study. Each report produced by the external contractor was first  presented in draft 

27 

 
form and subjected to a review and comments by the Commission services. The external study 
was also presented to civil society stakeholders in the context of the Civil Society Dialogue.  

28 

 
 
 
ANNEX III. SUMMARY OF BASELINES FOR EACH COUNTRY ACCORDING TO RELEVANT EVALUATION CRITERIA 

Partner 
country 

Baseline 
Period 

Pre-2017 

Canada 
(EU-Canada 
CETA) 

MEA Ratification and Compliance at Baseline14 

Regulatory cooperation at baseline 

• All focus MEAs already ratified at baseline 
• Significant climate actions in support of Paris Agreement at 
provincial and federal levels, but rising emissions from oil & 
gas sector; lack of cohesive national climate policy 

• Largely compliant with CITES with robust legal framework 

and active participation 

• Robust legal framework for biodiversity conservation with 

some implementation gaps, including scale of protected areas, 
Aichi targets, coordination between provinces and federal 
government 

•  Key cooperation on MEAs, including on Paris Agreement, Montreal 

Protocol, CBD and FLEGT 

• Cooperation in ETS and carbon pricing 

annual 
in  EGS  at 
(Millions 

Bilateral 
Trade 
baseline 
EUR)15 
€235.4 
exports) 
€874.8 (EU exports) 

(Canada 

Pre-2013 

Costa Rica 
(EU-Central 
America AA) 

• All focus MEAs already ratified at baseline 
• Non-Annex I country under Kyoto Protocol (KP); strong 

investment in renewable energy and robust reforestation efforts 
and sustainable forest management; domestic policies and 
initiatives consistent with broader objectives of KP 

•  Environmental sustainability and climate not explicitly referenced as a 
major area of cooperation under the EU’s 2007-13 regional and country 
strategy, though these remained key cross-cutting areas of importance. 
Most notable cooperative initiative launched was EUROCLIMA (now 
EUROCLIMA+) 

(Costa  Rica 

€0.9 
exports) 
€35.8 (EU exports) 

• Well-functioning and compliant Party to CITES with robust 
legal framework, effective institutional arrangements, regular 
reporting and active international cooperation 

• Seen as model for developing countries in compliance with 
CBD: strong policy commitments, effective institutional 
frameworks and innovative conservation programmes; some 
challenges in managing biodiversity in non-protected 
landscapes and in balancing development with conservation  

14 Focussing on the Paris Agreement, CITES and CBD 
15 Annual averages based on 5-year period preceding implementation of the agreement.  

29 

 
 
 
 
 
Pre-2014 

Georgia  
(EU-Georgia 
DCFTA) 

• All focus MEAs already ratified at baseline 
• Non-Annex I party under Kyoto Protocol; largely in line with 

expectations with successful fulfilment of reporting 
requirements and progress in building national policy 
framework; improvement needed in enhancing quality and 
consistency of data and expanding domestic capacity to 
implement comprehensive climate change measures 
• Formal compliance with CITES generally regarded as 

satisfactory; some enforcement challenges 

• Formally compliant with CBD obligations but implementation 
challenges resulting from limited capacity, resource constraints 
and coordination difficulties across sectors  

•  Cooperation under the Eastern Partnership (EaP) and European 

Neighbourhood Policy (ENP).  

€0.5 (Georgia exports) 
€34.1 (EU exports) 

• ENP Action Plan (2006-2011) prioritised environmental protection, 
including commitments to strengthen environmental governance and 
legislation; improve waste management and water quality; and promote 
renewable energy and energy efficiency.  

• EaP Environment and Climate Change Platform launched in 2009 to 

facilitate regional dialogue and cooperation on issues such as 
biodiversity, climate change adaptation and sustainable resource 
management.  

• European Neighbourhood and Partnership Instrument allocated €12.3 
million to Georgia’s environmental sector under the 2007-2013 ENPI 
funding cycle. Key projects included sustainable water resource 
management, forest protection and biodiversity conservation.  

• EU assisted Georgia in drafting laws on air quality, waste management 

and EIAs to reflect EU directives 

Pre-2013 

Honduras 
(EU-Central 
America AA) 

• All focus MEAs already ratified at baseline 
• Non-Annex I party under KP; complied with reporting and 

policy obligations though progress challenged by resource and 
institutional constraints 

•  Under the 10th European Development Fund, Honduras received 

funding for projects to protect biodiversity, reduce deforestation and 
promote renewable energy as well as for disaster risk reduction.  

• Most notable cooperative initiative launched was EUROCLIMA (now 

(Honduras 

€0.1 
exports) 
€10.5 (EU exports) 

Pre-2019 

Japan 
(EU-Japan 
EPA) 

• Had enacted necessary laws, established designated 

enforcement agencies and fulfilled reporting obligations under 
CITES, but enforcement challenges stemming from limited 
resources and technical capacity 

• Clear commitment to CBD through formal compliance 

mechanisms, including ratification, strategic planning and 
international reporting; practical implementation uneven with 
challenges arising from limited resources, institutional 
constraints and development pressures.  
• All focus MEAs already ratified at baseline 
• Formal compliance with Paris Agreement but mixed 

performance on implementation. Moderate progress towards 
climate goals, with positive developments in innovation and 
technology, international cooperation and corporate initiatives; 
criticisms related to weak carbon pricing, coal expansion and 
slow progress on renewables and delayed release of its LTS 
• Established legal frameworks and enforcement mechanisms 
under CITES, but criticism related to domestic ivory market, 
fisheries practices and enforcement gaps 

EUROCLIMA+) 

•  Multilateral cooperation on Paris Agreement and CBD and through G7 

and G20 Summits 

• Clean energy and technology collaboration, including the EU-Japan 
Fuel Cell and Hydrogen Joint Undertaking and EU-Japan Energy 
Dialogue 

• Explored synergies between the EU’s ETS and Japan’s Carbon Pricing 

(Japan 

€3 467.8 
exports) 
€1 800.2 (EU exports) 

Scheme 

30 

 
 
• Largely compliant with formal requirements under CBD, 

maintaining active engagement in international discussions and 
updating policies in response to global targets; concerns over 
continued declines in certain ecosystems, insufficient progress 
in some Aichi Target areas and need for better coordination 
among stakeholders 

Pre-2013 

• All focus MEAs already ratified at baseline 
• Non-Annex I Party to Kyoto Protocol. Generally met 

Peru 
(EU-Andean 
FTA) 

procedural requirements (submitted national communications 
and GHG inventories) but faced challenges from limited 
resources and technical capacity for comprehensive data 
collection and monitoring of GHG emissions. Developed 
national policies and strategies aimed at mitigation and 
adaptation aligned with KP.  

• Broadly compliant with CITES, but enforcement and 

implementation challenges due to limited financial and 
technical resources – particularly in remote and less accessible 
regions 

• Moderate progress in CBD. Established a legal framework for 
biodiversity conservation and indigenous rights, expanded 
protected areas and pioneered community-based conservation 
models. Implementation challenges from limited institutional 
capacity and funding for enforcement; persistent illegal 
activities (logging, mining) undermined conservation efforts; 
slow progress on integrating biodiversity into sectoral policies.  

• All focus MEAs already ratified at baseline 
• Formal compliance with procedural and reporting requirements 

of Paris Agreement; some critiques of the ambition of its 
targets 

• Mixed level of compliance with CITES 
• Strong record of compliance with CBD 

Pre-2019 

Singapore 
(EU-
Singapore 
FTA) 

• Cooperation through EUROCLIMA on projects related to climate 

adaptation, mitigation and policy dialogue 

• Support to combat illegal logging through FLEGT and REDD+ 
• Under 10th EDF (2008-2013), Peru received EU support for 

biodiversity conservation, sustainable agriculture, water management 

• EU provided technical assistance to Peru’s Environment Ministry 

(MINAM) to improve environmental governance, including through 
aligning Peru’s environmental laws with international standards and 
strengthen enforcement against illegal mining and logging.  

€0.4 (Peru exports) 
€86.4 (EU exports) 

(Singapore 

€559.3 
exports) 
€1 153.6 (EU exports) 

• Cooperation under the ASEAN-EU Dialogue on Environmental 
Sustainability, including Sustainable Use of Peatland and Haze 
Mitigation and the Biodiversity Conservation and Management 
Programme 

• Exchange of best practices on urban sustainability and smart cities 

under the EU Urban Agenda 

• Alignment of green finance frameworks through the Global Climate 

Change Alliance+ 

• Green Port collaboration 
• Knowledge sharing on Extended Producer Responsibility schemes for 

e-waste and packaging, recycling infrastructure development 

• Joint advocacy for global agreements to reduce marine plastic pollution 

and aligning with EU directives on single-use plastics 

• Cooperation on CITES enforcement 

31 

 
 
Pre-2020 

Viet Nam 
(EU-Viet 
Nam FTA) 

(Viet  Nam 

€438.0 
exports) 
€206.8 (EU exports 

• All focus MEAs already ratified at baseline 
• Strong formal adherence to procedural obligations of Paris 
Agreement, including ratification, NDC submission and 
regular reporting. Notable progress in domestic policy 
development and international cooperation. Implementation 
challenges due to resource and capacity constraints and in 
balancing economic development with long-term climate goals.   

• Compliant with formal requirements of CITES: necessary legal 
framework, designated authorities and reporting mechanisms in 
place. Uneven enforcement, with Viet Nam serving as a key 
transit hub and consumer of a number of trafficked species 
such as pangolins, rhino horns, elephant ivory and tiger parts. 

• Moderate compliance with CBD. Established legal 

frameworks, expanded protected areas and engaged in 
conservation initiatives. Significant challenges in the form of 
habitat loss, illegal wildlife trade and enforcement gaps 
(limited capacity for monitoring protected areas and 
prosecuting crimes as well as overlapping jurisdictions among 
agencies).  

• Cooperation under the ASEAN-EU Dialogue on Environmental 
Sustainability, including Sustainable Use of Peatland and Haze 
Mitigation and the Biodiversity Conservation and Management 
Programme 

• Negotiation of FLEGT-VPA 
• Technical assistance provided to align Viet Nam’s Green Growth 
Strategy (2012) with international climate goals, including energy 
efficiency targets and low-carbon urban planning 

• Under 10th EDF (2008-2013), EU allocated €156 million to Viet Nam 
for environmental projects, including in areas of sustainable forest 
management and biodiversity conservation, water resource 
management and pollution control and renewable energy development 

• SWITCH-Asia Programme supported sustainable consumption and 
production practices in Viet Namese industries, aligning regulations 
with EU circular economy principles 

• Cooperation on Paris Agreement and CITES 
• EU-Viet Nam Energy Initiative provided expertise to modernise Viet 

Nam’s energy sector, including energy efficiency standards 

• Training programmes for Viet Namese officials on EU environmental 

regulations 

• Dialogues on reducing marine plastic pollution and alignment with 

EU’s Single-Use Plastics Directive 

32 

 
 
 
 
 
ANNEX IV. MEA RATIFICATION AND IMPLEMENTATION 

The Comprehensive Economic and Trade Agreement (CETA) with Canada 

Negotiated  since  2009  and  provisionally  applied  since  2017,  CETA  was  one  of  the  first  trade 
agreements to incorporate the new TSD approach, featuring stronger environmental provisions than 
earlier  agreements with  the Republic of Korea or the Andean Community.16 Canada has  high  per 
capita CO₂ emissions due to extensive fossil fuel use for transportation and heating. Its vast boreal 
forests are facing increasing threats from wildfires and climate change, leading to significant national 
conservation  efforts,  including  the  2030  National  Biodiversity  Strategy.  The  Arctic  and  Northern 
Policy Framework was introduced to enhance the resilience of Canada’s northern ecosystems. Canada 
has long been active in international environmental governance, having been the first industrialized 
country to  sign  the Convention on Biological  Diversity.  While it has integrated  circular economy 
principles into various sectors, it has yet to establish a dedicated national circular economy strategy. 

Canada has been proactive in meeting its climate commitments under the Paris Agreement, updating 
its NDCs to target a 40-45% reduction in emissions by 2030 and a net-zero goal by 2050. CETA’s 
impact  on  climate  policy  has  been  indirect,  with  discussions  in  the  Committee  on  Trade  and 
Sustainable  Development  (CTSD)  primarily  focused  on  clean  technology  rather  than  NDC 
implementation.  However,  the  CTSD  and  the  CETA  Joint  Committee  also  recalled  the  parties’ 
commitment to effectively implement the Paris Agreement. Both committees have been instrumental 
in  coordinating  joint  efforts  in  multilateral  fora  to  foster  sustainable  trade  and  addressing  climate 
change.  

Canada  is  compliant  with  CITES  reporting  requirements,  with  its  biennial  and  annual  reports 
submitted  on  time,  and  it  has  taken  additional  steps  to  regulate  the  trade  of  elephant  ivory  and 
rhinoceros’  horn.  However,  discussions  under  CETA’s  CTSD  meetings  have  not  covered  CITES 
implementation in detail. Regarding the Convention on Biological Diversity (CBD), Canada’s last 
National Biodiversity Strategy and Action Plan (NBSAP) was submitted in 2024.  

The EU-Central America Association Agreement: Costa Rica  

Signed in  2012 and with  its trade pillar temporarily in  force since 2013, the EU-Central  America 
Association Agreement formalized long-standing trade and political relations between the EU and 
Costa Rica, following earlier frameworks such as the 1999 Framework Cooperation Agreement and 
the  2003  Political  Dialogue  and  Cooperation  Agreement.  Costa  Rica  is  the  EU’s  most  significant 
trade  partner  in  Central  America  and  is  widely  regarded  as  a  leader  in  environmental  policy, 
particularly in biodiversity conservation and forest protection, which are critical to its tourism-driven 
economy. The country has actively pursued carbon neutrality, leveraging its extensive carbon sinks 
to offset emissions. Costa Rica’s National Decarbonisation Plan and National Programme for Carbon 
Neutrality highlight its ambitious climate policies, though challenges remain in modernizing water 

16 Blot E. & Kettunen M, 2021, Environmental credentials of EU trade policy: A comparative analysis of EU free trade 
agreements. Institute for European Environmental Policy.  

33 

 
 
 
 
 
and waste management infrastructure, strengthening climate adaptation investments, and reforming 
its environmental permitting system.17 

Costa  Rica  ratified  the  Paris  Agreement  in  2016.  The  Climate  Action  Tracker  rates  Costa  Rica’s 
climate commitments as “Almost sufficient,” indicating that while its policies align with the Paris 
Agreement’s 1.5°C goal, additional measures are needed to strengthen implementation. Despite its 
leadership in conservation, Costa Rica faces challenges in securing financial and technical resources 
for robust emissions reporting and mitigation projects.18 The country has actively engaged in CBD 
processes, with a well-structured NBSAP that includes ambitious biodiversity targets aligned with 
global frameworks. Costa Rica has also implemented multiple policies under CITES, but difficulties 
remain in transitioning to electronic permitting systems.  

The EU-Central America Association Agreement: Honduras 

The trade pillar of the EU-Central America Association Agreement, temporarily in force since 2013, 
provided a framework for trade and environmental cooperation between Honduras and the EU. As a 
small  developing  economy  with  relatively  low  emissions,  Honduras  faces  severe  environmental 
pressures, particularly in the “Dry Corridor,” where drought and water scarcity are worsening. The 
country’s energy sector remains heavily dependent  on fossil fuels  and biomass, while agricultural 
expansion, particularly in coffee, palm oil, and logging industries, has led to significant deforestation. 
Illegal wildlife trafficking, primarily in birds and reptiles, further threatens biodiversity. Although 
Honduras  has  adopted  a  National  Plan  for  Decarbonisation  and  a  Climate  Change  Law,  its 
implementation capacity is limited by financial constraints and weak institutional frameworks. 

Honduras ratified the Paris Agreement in 2016 and has since increased its climate ambitions, with an 
updated  NDC  submitted  in  2021  emphasizing  emissions  reductions,  reforestation,  and  adaptation 
measures.  The  EU  has  provided  technical  assistance  through  DG  INTPA.19  With  regard  to 
biodiversity, the Agreement spurred bilateral efforts aimed at forest protection, including the signing 
of the VPA-FLEGT in 2021 and a subsequent Forest Partnership Memorandum of Understanding in 
2023 between the EU and Honduras. However, compliance with the CBD more broadly has been 
mixed, with Honduras submitting national reports but struggling with implementation due to weak 
legislative frameworks and inadequate monitoring.  

While Honduras is a CITES signatory, enforcement remains challenging, particularly regarding the 
disposal of confiscated specimens and ensuring proper care for trafficked wildlife. Despite its lower 
level of biodiversity commitment compared to regional counterparts such as Costa Rica, Honduras 
has actively engaged with the EU on deforestation issues and was the first Latin American country to 
sign a Voluntary Partnership Agreement (VPA) on FLEGT in 2021.  

EU-Viet Nam Free Trade Agreement (EVFTA) – Viet Nam 

Signed  in  2019,  the  EVFTA  entered  into  force  in  2020.  It  was  the  most  comprehensive  trade 
agreement  between  the  EU  and  a  developing  country20  until  the  conclusion  of  the  EU-Kenya 

17 OECD. 2023. OECD Environmental Performance Reviews: Costa Rica 2023. Available at the following link. As part 
of the National Decarbonisation Plan, Costa Rica is developing sectoral strategies to reduce the amount of organic waste 
going to landfills; increase the country’s recycling capacity, and reduce emissions from waste. The plan is available at 
the following link.  
18 See BUR 2019. Available at the following link.  
19 EU Commission. DG INTPA. 2022. Multiannual indicative programme 2021-2027 for Honduras – Annex. Available 
at the following link. 
20 Ha Hai Hoang. 2020. Understanding the EU–Viet Nam Free Trade Agreement. East Asia Forum. Available at the 
following link.  

34 

 
 
Economic Partnership Agreement21. MEAs are included in Chapter 13 of the agreement, specifically 
through  Articles  13.5  to  13.7.  Viet  Nam  is  highly  vulnerable  to  climate  risks,  with  emissions 
increasing fivefold over the past two decades due to surging electricity demand, primarily from coal-
fired power plants.22 The energy sector accounts for more than half of the country's total emissions, 
followed by agriculture, industrial processes, and waste management. Viet Nam is also one of the 
world’s  most  biodiverse  countries,  but  deforestation,  urbanization,  and  illegal  wildlife  trade  place 
increasing pressure on its ecosystems. Before the EVFTA, Viet Nam had already adopted key national 
policies,  including  the  National  Strategy  on  Climate  Change  and  the  Viet  Nam  Green  Growth 
Strategy,  as  well  as  ratified  major  multilateral  environmental  agreements  (MEAs)  such  as  the 
UNFCCC, CBD, and CITES.  

Viet Nam has significantly increased its climate ambition since the EVFTA took effect, pledging at 
COP26 to achieve net-zero emissions by 2050. The country updated its NDC in 2022 but still falls 
into the “critically insufficient” category under the Climate Action Tracker, indicating misalignment 
with  the  Paris  Agreement’s  1.5°C  target.  While  Viet  Nam  has  made  some  progress,  including 
adopting  a  National  Climate  Change  Strategy  and  launching  an  Emissions  Trading  System,  weak 
measurement, reporting, and verification (MRV) systems hinder effective emissions tracking.  

Discussions under the EVFTA’s TSD Committee have focused on climate policy and clean energy 
transitions, but major initiatives, such as the Just Energy Transition Partnership (JETP), have been 
established outside the agreement’s framework. Regarding biodiversity, Viet Nam has strengthened 
its policy framework ahead of the Kunming-Montreal Global Biodiversity Framework but struggles 
with implementation due to financial and capacity limitations. In particular, while a past objective of 
designating 7% of the country’s land area as under protection is nearly achieved, the achievement of 
more  updated  targets—according  to  both  domestic  legislation  such  as  the  Country’s  national 
biodiversity strategy and international commitments such as the CBD Aichi Target 11—remain to be 
achieved.  

With regard to forestry activities more specifically, Viet Nam signed a VPA with the EU in 2019. 
However, the regulatory picture is not yet complete as a revision of the national decree implementing 
the FLEGT legislation is needed to address illegal sourcing as a major loophole of the regulation. 

Finally,  while  Viet  Nam  has  enacted  stricter  laws  to  combat  wildlife  trafficking  under  CITES—
including  the  2017  amendment  of  the  penal  code  and  the  Law  on  Forestry  of  the  same  year—
enforcement  remains  inconsistent.  There  is  limited  recognition  of  the  international  criminal 
dimensions of IWT and a lack of follow-up investigations to dismantle trafficking networks. Low-
deterrence  penalties  and  low  conviction  rates  further  undermine  enforcement  efforts,  while  local 
authorities and law enforcement agencies often face capacity and resource constraints. Additionally, 
international  and  regional  cooperation  on  IWT  remains  limited,  reducing  information  sharing  and 
coordinated action. Recent crackdowns on environmental NGOs have further weakened the ability to 
monitor and implement CITES commitments. The country thus continues to serve as a transit point 
for the illegal trade of endangered species.  

Deep and Comprehensive Free Trade Area (DCFTA) – Georgia 

The  EU-Georgia  Association  Agreement,  including  the  DCFTA,  was  signed  in  2014  and 
provisionally  applied  from  September  of  that  year.  This  preferential  trade  regime  aims  to  align 
Georgia’s regulatory framework with EU standards and enhance market access. As a Non-Annex I 

21 Not covered by this evaluation as it entered into force on 1 July 2024. Official Journal L, 2024/1648, 1.7.2024 
22 Agarwal, V., Deffarges, J., Delteil, B., Francois, M., & Tara K. 2022. Charting a path for Viet Nam to achieve its net-
zero goals. McKinsey Insights. Available at the following link.  

35 

 
 
Party  to  the  UNFCCC, Georgia  ratified  the  Paris  Agreement  in  2017  and  has  since  committed  to 
reducing  domestic  emissions  by  35%  by  2030,  with  a  conditional  target  of  50-57%  reduction 
depending on international support. However, Georgia faces implementation challenges, including 
weak institutional coordination, lack of domestic financial resources, and gaps in GHG measurement 
and reporting.23 The country has made progress in aligning national policies with EU directives on 
energy  efficiency,  waste  management,  and  sustainability  but  struggles  with  enforcement.  In 
biodiversity conservation, Georgia has been a CBD signatory since 1994 and has updated its National 
Biodiversity Strategy and Action Plan (NBSAP) to cover new conservation priorities, but significant 
funding and capacity constraints remain. 

Since the DCFTA’s implementation, Georgia has strengthened its environmental commitments, with 
updated climate targets and long-term decarbonization plans. The TSD Sub-Committee has played a 
role  in  supporting  Georgia’s  environmental  compliance,  including  its  ratification  of  the  Kigali 
Amendment  to  the  Montreal  Protocol  in  2023.  However,  challenges  remain  in  translating  these 
commitments into action due to governance weaknesses and resource limitations. Georgia has made 
progress in aligning its environmental policies with EU directives, particularly in climate mitigation, 
energy efficiency, and biodiversity conservation, but enforcement remains patchy. The country is also 
a CITES party, though it faces difficulties in timely reporting and lacks fully developed compliance 
monitoring mechanisms.  

EU-Japan Economic Partnership Agreement (EPA) – Japan 

Negotiations for the EPA began in 2013 and were concluded in 2017, with the agreement entering 
into force in 2019. Japan, an industrialized economy, has historically had high CO₂ emissions, though 
these have declined over the past two decades. Following the Fukushima disaster, reliance on fossil 
fuels  increased,  leading  to  an  emissions  surge,  though  Japan  has  since  implemented  policies  to 
transition  toward  cleaner energy, including  an Emissions Trading  System  introduced in 2023 that 
would become mandatory from 2026. Japan ratified the Paris Agreement in 2016, committing to a 
46%  emissions  reduction  by  2030  and  carbon  neutrality  by  2050.  While  Japan  has  a  strong  legal 
framework  for  environmental  management,  enforcement  challenges  remain,  particularly  in  forest 
conservation  and  wildlife  protection.  The  EPA  includes  references  to  eight  MEAs  but  provides 
limited mechanisms for enforcement.24 

Japan has been largely compliant with its Paris Agreement obligations, submitting NDC updates on 
time, though independent reviews indicate that its policies are not fully aligned with 1.5°C targets. 
According to the recent OECD 2025 Environmental Performance Review, Japan raised its climate 
commitments but must accelerate GHG emission reductions. The 2030 target (-46% from the 2013 
peak  level)  and  2050  net-zero  goal  are  more  ambitious  than  previous  objectives.  While  GHG 
emissions fell by 19% from 2013 to 2022, a faster decline is needed to meet the targets.25 While the 
EPA provides a framework for environmental cooperation, CTSD discussions have mainly focused 
on information-sharing rather than implementation oversight. Japan has faced international scrutiny 
for violating CITES obligations regarding sei whale trade, and despite multiple reviews, the practice 
continues. Japan has timely submitted its CITES and CBD reports.  

EU-Singapore Free Trade Agreement (EUSFTA) – Singapore 

23 See, for instance, Government of Georgia. 2021. Fourth National Communication of Georgia under the UNFCCC. 
Available at the following link.  
24 Blot E. & Kettunen M, 2021, Environmental credentials of EU trade policy: A comparative analysis of EU free trade 
agreements. Institute for European Environmental Policy.  
25 https://www.oecd.org/en/publications/oecd-environmental-performance-reviews-japan-2025_583cab4c-en.html 

36 

 
 
The  EUSFTA,  which  came  into  force  in  2019,  stands  out  for  its  focus  on  renewable  energy  and 
sustainability  cooperation.  Singapore,  a  small  but  densely  populated  city-state,  faces  unique 
environmental  challenges,  particularly  in  reducing  industrial  emissions  and  increasing  renewable 
energy  adoption.  With  CO₂  emissions  per  capita  at  8.35  tonnes  in  2021—higher  than  the  EU 
average—Singapore  struggles  with  decarbonization  due  to  its  reliance  on  natural  gas.  While  the 
country has made significant advancements in waste and water management, progress in transitioning 
to  low-carbon  energy has been slow.  Singapore ratified the Paris Agreement  in  2016 but  remains 
dependent on fossil fuels. 

Singapore’s climate policies have improved since the EUSFTA was signed. While the EU is in many 
instances  a  ‘first-mover’  in  terms  of  ambitious  environmental  protection  legislation,  Singapore  is 
often a first adopter in the Southeast Asian region, as was the case with a carbon pricing mechanism. 
As  such,  Singapore  plays  an  important  role  as  a  benchmark  for  other  ASEAN  countries.  Gaps  in 
decarbonisation efforts  remain, however. The Climate Action Tracker rates  Singapore’s efforts as 
“critically insufficient,”  with  its renewable energy share still below global  benchmarks. However, 
Singapore  has  made  strides  in  biodiversity  conservation,  updating  its  NBSAP  regularly  and 
implementing strong conservation measures. The country’s CITES compliance has been mixed, with 
administrative  bottlenecks  in  permit  issuance  and  a  lack  of  standardized  non-detriment  findings. 
Singapore remains a key hub for palm oil and timber exports, and new EU regulations, such as the 
EUDR, could significantly impact its trade flows.  

The EU-Andean Free Trade Agreement – Peru 

Signed  in  2012,  the  EU-Andean  Free  Trade  Agreement  reaffirmed  Peru’s  commitment  to 
international environmental governance. Since its implementation, Peru has ratified several MEAs, 
including the Paris Agreement (2016). However, emissions have continued to rise, and deforestation 
remains a concern. This was one of the reasons why another FTA—the US-Peru FTA—included a 
specific  forest  annex,  with  provisions  specifically  focusing  on  forestry  and  logging  activities  is 
directly linked to that pressure.26  

That being said, the increase in GHG emissions in Peru has been marginal since 2015, and Peru’s 
current policy efforts are rated “Almost sufficient” by the Climate Action Tracker, which indicates 
that Peru’s climate policies and action in 2030 are not yet consistent with the 1.5°C temperature limit 
but  could  be,  with  “moderate  improvements”.  Despite  ambitious  climate  policies,  Peru’s 
implementation capacity remains weak, with limited enforcement mechanisms. The country has yet 
to  submit  an  updated  NDC,  and  its  biodiversity  strategy  remains  outdated.  Without  stronger 
enforcement and monitoring systems, Peru’s environmental progress risks stalling. 

26 Another major difference with the EU-Andean agreement is that all provisions in the Environment Chapter are 
subject to the same dispute settlement procedures and enforcement mechanisms as commercial obligations. 

37 

 
 
 
 
 
 ANNEX V. TRADE IN GOODS  

Table A1: Development of EU-Canada trade in environmental goods pre-FTA and post-FTA implementation 
(2017), trade value in EUR million 

EU import 

Canada 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

27.2 

26.5 

25.0 

-8% 

Geothermal, hydro, 
solar and wind 
energy 

151.3 

160.9 

184.8 

22% 

Buildings equipment 

56.9 

74.5 

72.3 

Total extra-EU trade 

16,696.3 

18,173.4 

20,586.0 

27% 

23% 

-6% 

15% 

-3% 

13% 

EU export 

Canada 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

49.6 

69.6 

63.9 

29% 

Geothermal, hydro, 
solar and wind 
energy 

721.2 

742.8 

684.2 

-5% 

Buildings equipment 

104.0 

138.6 

155.3 

Total extra-EU trade 

29,119.5 

32,197.3 

35,302.0 

49% 

21% 

-8% 

-8% 

12% 

10% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment  - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

Table A2: Development of EU-Costa Rica trade in environmental goods pre-FTA and post-FTA 
implementation (2013), trade value in EUR million 

EU import 

Costa Rica 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

0.0 

0.1 

0.2 

470% 

65% 

Geothermal, hydro, 
solar and wind 
energy 

0.8 

1.1 

0.7 

-12% 

-40% 

Buildings equipment 

0.1 

0.2 

0.3 

293% 

Total extra-EU trade 

1,636.3 

1,609.4 

1,935.2 

18% 

81% 

20% 

38 

 
EU export 

Costa Rica 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

2.5 

4.0 

5.9 

137% 

47% 

Geothermal, hydro, 
solar and wind 
energy 

31.1 

50.0 

36.9 

18% 

-26% 

Buildings equipment 

2.2 

2.5 

5.6 

153% 

Total extra-EU trade 

691.4 

764.8 

879.6 

27% 

121% 

15% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment  - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

Table A3: Development of EU-Georgia trade in environmental goods pre-FTA and post-FTA implementation 
(2016), trade value in EUR million 

EU import 

Georgia 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

0.0 

0.0 

0.0 

153% 

112% 

Geothermal, hydro, 
solar and wind 
energy 

0.5 

0.3 

0.5 

Buildings equipment 

0.0 

0.0 

0.0 

Total extra-EU trade 

607.3 

491.1 

639.0 

1% 

6% 

5% 

45% 

127% 

30% 

EU export 

Georgia 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

5.2 

7.0 

8.6 

67% 

22% 

Geothermal, hydro, 
solar and wind 
energy 

25.4 

27.6 

23.5 

-8% 

-15% 

Buildings equipment 

3.5 

4.7 

5.8 

Total extra-EU trade 

1,885.4 

1,842.8 

1,878.6 

66% 

0% 

25% 

2% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment  - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

39 

 
 
 
Table A4: Development of EU-Honduras trade in environmental goods pre-FTA and post-FTA 
implementation (2013), trade value in EUR million 

EU import 

Honduras 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

0.0 

0.0 

0.0 

80% 

-61% 

Geothermal, hydro, 
solar and wind 
energy 

0.1 

0.0 

0.1 

-55% 

1267% 

Buildings equipment 

0.0 

0.0 

0.0 

206% 

Total extra-EU trade 

674.1 

631.0 

870.1 

29% 

-14% 

38% 

EU export 

Honduras 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

3.0 

3.6 

3.3 

12% 

-8% 

Geothermal, hydro, 
solar and wind 
energy 

6.6 

6.3 

21.4 

225% 

242% 

Buildings equipment 

0.9 

0.7 

1.1 

Total extra-EU trade 

309.3 

357.5 

427.7 

32% 

38% 

53% 

20% 

Source: Own elaboration based on Eurostat. Note: Averages were calculated to mitigate the impact of data gaps and to 
compensate for fluctuations in values. Average trade values include the year of implementation. 

Table A5: Development of EU-Japan trade in environmental goods pre-FTA and post-FTA implementation 
(2019), trade value in EUR million 

EU import 

Japan 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

264.1 

274.1 

292.2 

11% 

Geothermal, hydro, 
solar and wind 
energy 

2,683.7 

2,742.7 

3,276.1 

22% 

Buildings equipment 

520.0 

559.5 

539.9 

Total extra-EU trade 

57,118.6 

63,031.2 

64,096.4 

4% 

12% 

7% 

19% 

-4% 

2% 

EU export 

40 

 
 
Japan 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

85.8 

114.8 

142.0 

65% 

Geothermal, hydro, 
solar and wind 
energy 

1,472.7 

1,661.4 

1,655.7 

12% 

Buildings equipment 

241.7 

297.2 

261.7 

Total extra-EU trade 

55,499.6 

62,628.4 

63,146.8 

8% 

14% 

24% 

0% 

-12% 

1% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

Table A6: Development of EU-Peru trade in environmental goods pre-FTA and post-FTA implementation 
(2013), trade value in EUR million 

EU import 

Peru 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

0.0 

0.0 

0.1 

596% 

484% 

Geothermal, hydro, 
solar and wind 
energy 

0.3 

0.5 

0.6 

75% 

12% 

Buildings equipment 

0.1 

0.0 

0.2 

177% 

Total extra-EU trade 

5,009.1 

5,002.8 

4,988.3 

0% 

398% 

0% 

EU export 

Peru 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

17.7 

12.8 

14.9 

-16% 

Geothermal, hydro, 
solar and wind 
energy 

61.6 

89.6 

95.4 

55% 

Buildings equipment 

7.1 

7.7 

14.6 

105% 

Total extra-EU trade 

2,561.2 

3,305.6 

3,420.3 

34% 

16% 

7% 

91% 

3% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

41 

 
 
 
Table A7: Development of EU-Singapore trade in environmental goods pre-FTA and post-FTA 
implementation (2019), trade value in EUR million 

EU import 

Singapore 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

5.7 

6.6 

15.1 

164% 

131% 

Geothermal, hydro, 
solar and wind 
energy 

494.4 

499.3 

889.5 

80% 

Buildings equipment 

59.2 

45.2 

55.6 

Total extra-EU trade 

17,807.6 

17,993.6 

18,339.7 

-6% 

3% 

78% 

23% 

2% 

EU export 

Singapore 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

95.7 

87.2 

108.2 

13% 

24% 

Geothermal, hydro, 
solar and wind 
energy 

932.6 

1,073.3 

1,113.7 

19% 

Buildings equipment 

125.3 

138.8 

134.6 

Total extra-EU trade 

27,668.4 

28,894.5 

28,831.0 

7% 

4% 

4% 

-3% 

0% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment - Draft final report - Annexes I to V of the 
main  report,  page  73.  Note:  Averages  were  calculated  to  mitigate  the  impact  of  data  gaps  and  to  compensate  for 
fluctuations in values. Average trade values include the year of implementation. 

Table A8: Development of EU-Vietnam trade in environmental goods pre-FTA and post-FTA implementation 
(2020), trade value in EUR million 

EU import 

Vietnam 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

4Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

1.9 

3.4 

6.2 

230% 

Geothermal, hydro, 
solar and wind 
energy 

423.0 

363.6 

476.7 

13% 

Buildings equipment 

13.1 

20.1 

35.2 

169% 

Total extra-EU trade 

31,832.1 

34,541.7 

43,063.7 

35% 

81% 

31% 

75% 

25% 

EU export 

42 

 
 
Vietnam 

5Y-average 
pre-FTA 

Year of 
entering into 
force 

5Y-average 
post FTA 

Percentage change 
‘pre-FTA’ to  ‘post-
FTA’ 

Percentage change ‘year 
of entering into force’ to  
‘post-FTA’ 

Energy efficiency 

26.9 

34.8 

34.8 

29% 

0% 

Geothermal, hydro, 
solar and wind 
energy 

143.4 

157.1 

320.4 

123% 

104% 

Buildings equipment 

36.5 

37.1 

39.6 

Total extra-EU trade 

9,826.7 

8,773.4 

10,886.8 

8% 

11% 

7% 

24% 

Source: Ex-post evaluation on the impact of EU FTAs on the environment - Draft final report - Annexes I to V of the 
main report, page 73.: Averages were calculated to mitigate the impact of data gaps and to compensate for fluctuations 
in values. Average trade values include the year of implementation. 

43 

 
 
 
ANNEX VI. EVALUATION MATRIX AND, WHERE RELEVANT, DETAILS ON ANSWERS TO THE EVALUATION QUESTIONS (BY CRITERION) 

The following pages report the evaluation matrix supporting the ex-post evaluation.  

Effectiveness and impact 
EQ1: To what extent have the objectives of the environmental provisions of the Agreements been achieved? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

1.1 The extent to which the Agreements have promoted 
the ratification and implementation of MEAs; 
1.2 The extent to which environmental and climate-
related regulatory cooperation has occurred 
between the Parties; 

1.3 The extent to which environmental and climate-

related regulatory cooperation has led to levelling 
up in partner countries; 

1.4 The extent to which EU market access requirements 
have promoted adoption of relevant EU and 
international environmental/climate standards; 

1.5 The extent to which EU FTAs selected have 

promoted the diffusion of EGS via preferential 
market access, public procurement, and investment; 

1.6 The extent to which the EU FTAs selected have 

ensured non-regression in environmental and 
climate-related rules, regulations and policies; 

1.7 The extent to which public participation has been 

promoted in environmental matters covered by the 
FTAs selected, notably across thematic clusters;  

- Ratification of MEAs (pre- and post-ratification of the Agreements); 
- Level of implementation and compliance with MEAs; 
- Increase in bilateral and multilateral initiatives and fora related to the environment 
and climate, e.g. regulatory cooperation initiatives on trade in EGS; participation in 
international standard-setting fora such as the international partnerships of CEN and 
CEN-CENELEC;27 
- Expansion in the scale and scope of regulatory cooperation under existing bilateral 
initiatives, including the review, or the adoption of new initiatives; 
- Increase in technical assistance, training, and person-to-person exchanges on best 
practices; 
- Environment and climate-related domestic policy and regulatory developments in 
FTA partners; 
- Adoption of EU and/or international climate and environmental standards by FTA 
partners; 
- Increase in EU exports, imports, and investment in goods and services that can be 
characterised as EGS; 
- Removal of non-tariff barriers (NTBs) related to EGS; 
- Increase in patenting and/or other innovation outputs in environmental 
technologies in selected countries; 

- Desk research, including the review of existing FTA impact assessments, 
reports from international organisations/ academic/ think tanks, DAG 
memoranda and committee declarations and/or statements, minutes from 
bilateral and international fora and initiatives; 
- Legal/regulatory analysis (e.g. based on InforMEA and Biosafety Clearing 
House data); 
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 
- Existing classification efforts of EGS, including Annex 22A (Environmental 
Goods List) of the UK-New Zealand FTA and Ecorys (2023).  
- UN-COMTRADE trade data;  
- Case studies 

27 CEN refers to the European Committee for Standardization (CEN) and CENELEC refers to the European Committee for Electrotechnical Standardization (CENELEC). For more 
information, see https://www.cencenelec.eu/european-standardization/international-cooperation/global-outreach/  

44 

 
 
 
 
 
Judgement criteria 

Indicators 

Sources of evidence and methods 

1.8 The extent to which EU FTA partners have 

experienced an increase in technology diffusion in 
environmental technologies. 

- Changes in green/climate-friendly technologies, goods and services trade via 
preferential market access, public procurement, technology transfer and investment 
promoted by the FTAs; 
- Instances of alliance-building with partner countries within multilateral fora or in 
developing sectoral agreements; 
- Realisation of environmental and climate-related aspects of TSD Committee 
Action Plans; 

EQ 2: To what extent has the implementation of the environmental provisions of the Agreements contributed positively to the environment, including the climate? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

2.1 The extent to which MEA ratification and compliance 
has produced positive outcomes in the four thematic 
clusters under study (biodiversity, climate, circular 
economy, deforestation)t; 

2.2 The extent to which regulatory cooperation has 

demonstrably led to environmental- and climate-
friendly outcomes, notably across thematic clusters; 

2.3 The extent to which green/climate-friendly 

technologies, goods and services have diffused in 
partner countries; 

2.4 The extent to which environmental parameters have 

not regressed in comparison to baseline;  

2.5 The extent to which the civil society participation has 
contributed to positive environmental outcomes, 
notably across thematic clusters; 

- Increase in regulatory cooperation resulting from FTA and qualitative analysis 
of its demonstrable outcomes;  
- Change in EU exports of EGS to FTA partners; 
- Change in imports of EGS in FTA partners; 
- Change in key environmental performance indicators, such as carbon emissions, 
deforestation, biodiversity loss; 
- Observed changes in environmental parameters related to TSD Committee 
Action Plans and DAGs; 
- Resolution of environment and climate-related issues raised by DAGs, or 
progress in the treatment of these issues (including progress thereto). 

- Desk research including the review of existing FTA impact assessments, 
reports from international organisations/ academic/ think tanks 
- UNFCCC BTRs, TRs, REDD+ reports, national biodiversity strategies, 
CITES implementation reports  
- Quantitative data analysis of UN-COMTRADE trade data and national 
statistical accounts;  
- Legal/regulatory analysis; 
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 
- Case studies. 

EQ 3: What are the implementing factors of the Agreements that are influencing (positively or negatively) the impact on the environment, including the climate? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

3.1 The extent to which observed outcomes across key 
parameters can be attributed, at least in part, to 
implementing mechanisms including: 

- Changes or non-regression in, among others, laws, rules, and regulations, 
environmental protection measures, policies, international commitments; as 

- Desk research including the review of the minutes, reports, and other 
deliverables emerging from CSDs, Sub-Committees, DAGs, and other bilateral 
and multilateral fora;  

45 

 
 
 
 
 
 
 
 
- Regulatory cooperation mechanisms; 
- TSD sub-committees; 
- Civil Society Dialogues; 
- Domestic Advisory Groups; 
- Dispute settlement mechanisms (when relevant). 

raised, promoted, monitored, addressed, challenged and/or disputed through the 
implementing mechanisms.  
- Increase in bilateral and multilateral initiatives and fora related to the 
environment and climate, e.g. regulatory cooperation initiatives on trade in EGS; 
participation in international standard-setting for a; 
- Increase in technical assistance, training, and person-to-person exchanges on 
best practices; 

- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 
- Case studies.  

EQ 4: Has implementation of the Agreements had unintended positive or negative consequences (including on the economic, social and human rights dimensions), and if so, which ones? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

4.1 The extent to which environmental provisions in EU 
FTAs have promoted the adoption of relevant EU and 
international human rights and labour standards. 

4.2 The extent to which environmental provisions in EU 
FTAs have created trade diversion or trade deflection in 
partner countries. 

4.3 The extent to which environmental provisions in EU 
FTAs have increased investment flows to partner 
countries. 

- Indication of unintended economic impacts of TSD provisions in EU and/or 
partner countries (e.g. reduction in income, exports and/or imports, increase in 
unemployment.);  
- Indication of unintended social impacts of TSD provisions in EU and/or partner 
countries (e.g. reduction in quality of jobs, degradation in social protection, etc.) ;  
- Indication of unintended environmental impacts of TSD provisions in EU and/or 
partner countries (e.g. polluting economic activities, deforestation, etc.);  
- Indication of unintended human rights impacts of TSD provisions in EU and/or 
partner countries (e.g. child labour, labour protection, political freedom, etc.); 

- Economic performance indicators (from national statistical accounts, WTO 
WITS, etc) and international benchmark indices such as the Fraser economic and 
human freedom index 
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 
- Case studies 

46 

 
 
 
 
 
 
 
 
 
 
 
 
 
Efficiency 
EQ 5: To what extent are the costs associated with implementation of the environmental provisions of the Agreements proportionate to the benefits it has generated? Is the distribution of both 
costs and benefits proportionate among different stakeholders’ groups and interests? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

5.1 The extent to which environmental, economic, social 
benefits linked to the TSD provisions outweigh the 
costs of implementation, overall and for specific 
groups; 

5.2 The extent to which the costs arising from the 

implementing factors are demonstrably higher (lower) 
than the observed benefits of the environmental 
provisions; 

5.3 The extent to which the implementing factors are 

burdensome, and the extent to which they may be 
simplified; 

5.4 The extent to which the Agreements have built on 
existing forms of cooperation, assistance, and 
institutional dialogue, thus reducing duplication of 
effort.  

- Costs of setting up and maintaining the implementing mechanisms related to 
the TSD provisions; 
- Identification of stakeholder groups (particularly vulnerable group) that have 
been positively or negatively affected by the Agreements; 
- Distribution of socio-economic benefits and costs among different societal 
groups; 
- Presence of unnecessary institutional, regulatory, administrative or procedural 
requirements;  
- The time needed to realise the objectives compared to original plan or 
expectations. 

- Desk Research;  
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 
- Case studies. 

47 

 
 
 
 
 
Coherence 
EQ 6: To what extent have the implementing factors of environmental provisions of the Agreements been coherent with EU trade and sustainability policies and in particular, with the EU’s 
commitment to sustainable development in trade policies as a contribution to the attainment of the SDGs? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

- Examples of convergence, contradicting points, and synergies (or lack 
thereof) in the issues raised and follow-up activities of the different 
implementing factors, through the analysis of their number, type, and 
extent/relevance 
- Examples of synergies with key EU policies and commitments, EU wider 
engagement with trade partners etc , or lack thereof; through the analysis of 
their number, type, and extent/relevance. 

- Lega/regulatory analysis  
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and survey; 

6.1 The extent to which the key areas or issues of focus in 
the implementing mechanisms' are aligned with (or 
contradictory) key EU sustainable trade objectives, 
notably the TSD policy; 
6.2 The extent to which the key issues focused by the 
implementing factors of environmental and climate clauses 
are aligned (or contradictory) to key EU policies and 
commitments towards the attainment of SDGs (e.g. for 
Biodiversity and ecosystems, Climate Change, Forests, 
Oceans, Sustainable Food Systems); 
6.3 The extent to which key issues focused by the 
implementing factors of environmental and climate clauses 
are aligned (or contradictory) to promote synergies with 
the wider EU engagement with trade partners (other 
projects, dialogues, assistance, cooperation) focused on 
TSD policies and commitments towards the attainment of 
SDGs; 

Relevance 
EQ 7: To what extent do the provisions and implementing factors of the Agreements continue to be relevant in order to address the current environmental needs and issues? 

Judgement criteria 

Indicators 

Sources of evidence and methods 

7.1 The extent to which current environmental needs or 

issues can be addressed on the basis of provisions and 
implementing factors of the 9 EU FTAs analysed; 
 7.2 The extent to which new or more ambitious provisions 
and implementing factors are needed to address 
current environmental needs or issues. 

 - Identification of current environmental key issues, needs and gaps across 
trade partners in TSD priority areas; 
- Identification of key policy priorities and gaps across trade partners in TSD 
priority areas; 
- Examples (analysis of number, type, and extent/relevance) of alignment (or 
lack thereof) in environmental and climate chapters and implementing factors 
with key issues and policy priorities; 

- Desk Research  
- Stakeholder consultations, including interviews, focus group discussions 
(FGDs), participation in civil society dialogues and surveys; 
- Case studies 

48 

 
 
 
 
 
7.3 The extent to which the implementing factors are 

aligned to multilateral environmental agreements and 
standards. 

- Existence of clauses regulating access to data (or removing restrictions to data 
localisation) in existing agreements.  

49 

 
 
 
 
ANNEX VII. STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

AIV.1 Introduction 

Stakeholder consultations have been a critical input on this evaluation. The consultations 
support all parts of the analysis (all evaluation questions; all cross-cutting parameters; and 
all case studies). The consultations served to engage with all stakeholders; contribute to 
the  transparency  of  the  evaluation;  validate  (or  disprove)  hypotheses  and  address 
evaluation questions; and identify priority areas and lessons learned.  

The stakeholders were selected with a view on the following elements:  

•  Sectoral  Representation:  the  contractor  identified  stakeholders  from  a  wide 
variety of relevant sectors that may be directly or indirectly impacted by the FTAs. 
This  includes  environmental  organisations,  industry  associations,  labour  unions, 
government  agencies,  research  institutions,  local  communities,  and  civil  society 
groups working on environmental issues. 

•  Geographical  Scope:  Balanced  geographical  representation  has  been  ensured, 
considering both EU member states and partner countries involved in the FTAs. 
Representation  from  regions  and  communities  that  may  experience  diverse 
environmental impacts has been ensured. 

•  Expertise  and  Knowledge:  Relevant  stakeholders  possessing  expertise  and 
knowledge in environmental matters, trade policy, sustainable development, and 
specific industries affected by the FTAs. 

•  Affected Groups: Stakeholders representing communities, indigenous groups, or 
marginalized  populations  who  may  be  disproportionately  affected  by  the 
environmental impacts of the FTAs have been taken into account. 

The evaluation focussed on the following target groups:  

Table AIV.1. Target groups’ membership 

Target group 

Sub-group 

Target group 1 

Target group 2 

Public 
administration 

Civil society  

Public 
administration 

Target group 3   Civil society 

Stakeholders 
European Commission (incl. DG TRADE, DG CLIMA, DG 
ENV, DG INTPA) 
EUDs 
Members of the DAGs 
Universities and think tanks  
Government Ministries and Agencies (Environment, 
Conservation, Trade, Social Affairs, Economy) 
WTO Ambassadors  
NGOs, especially active on environmental, social, and human 
rights issues 
Trade unions 

50 

 
 
 
Target group 4 

Private sector  

Business associations, SMEs 

Universities and think tanks 

AIV.2 Overview of overall stakeholder involvement  

In what follows, the various consultation tools used in this evaluation are described. Details 
are  provided  on  the  number  of  participants  per  consultation  tool,  as  well  as  on  the 
challenges encountered by the evaluation team. 

Interviews  

Given  the  broad  geographic  and  thematic  scope  of  this  evaluation,  in-depth,  semi-
structured interviews with stakeholders have represented the main consultation tool used 
in  this evaluation.  In total,  198 interviews  were  conducted, with  stakeholders  from  134 
organisations  and/or  institutions.  These  include  six  scoping  interviews  with  academic 
experts who were consulted at inception phase.  

While the majority of interviews were carried out with individual participants, in several 
cases, these took  place in  the form  of group interviews or discussions. The majority of 
interviews  were  held  virtually,  over  Microsoft  Teams.  Some  interviews,  particularly  in 
Honduras and Colombia, were held over the phone. Some team members based in partner 
countries,  as  well  as  country  experts  were  able  to  hold  physical  interviews.  Physical 
interviews were held in Japan, Viet Nam, Costa Rica, and Georgia, among other partner 
countries.  

The distribution of interviews across the four target groups is well-balanced for groups 1 
to 3, but there were relatively fewer interviews conducted with stakeholders categorised in 
target group 4, which includes business associations and SMEs.28 

28 It is important to note that this does not imply that the input from business organisations and SMEs are 
less represented across the gathered input from consulted stakeholders. In total, 7 business associations 
were consulted which are members of a Domestic Advisory Group of one of the FTA partner countries, 
resulting in being categorised under target group 1, rather than target group 4.  

51 

 
 
 
 
 
 
Figure AIV.1 Overview of conducted interviews per target group  

Target group 1

Target group 2

Target group 3

Target group 4

0

10

20

30

40

50

60

In terms of the country coverage of the interviews among the 8 focus countries, individual 
country interviews, encompassing stakeholders across target groups 1-4, range between 12 
and  20  interviews.  With  the  exception  of  Singapore,  where  considerable  difficulty  was 
experienced in securing interviews with local governmental administrations, NGOs, and 
business organisations.    

In total, 74 interviews were conducted covering cross-cutting issues and aggregate regions, 
as well as EU FTA partner countries beyond the 8 focus countries, including South Korea, 
Ecuador, Colombia, and Moldova, among others.  

Figure AIV.2: Country coverage of the conducted interviews 

Other FTA partners, EU, cross cutting

Japan

Vietnam

Honduras

Georgia

Costa Rica

Canada

Peru

Singapore

0

10

20

30

40

50

60

70

80

A challenge that the evaluation team encountered during the interviews was stakeholders’ 
limited awareness of the specific environmental provisions in EU FTAs. Particularly in 
partner countries, this was compounded by stakeholders appearing to be more aware of, 
and interested in, the recent EU autonomous measures such as the EUDR. 

52 

 
 
 
Civil Society Dialogue 

The  civil  society  dialogue  meetings  held  by  DG  TRADE  provided  an  opportunity  to 
receive  additional  input  from  EU  civil  society  on  the  overall  methodology  of  the 
evaluation, as well as on its preliminary findings. Two meetings were organised with civil 
society: on the 10th of January, 2024; and on the 25th of February, 2025.  During these 
meetings, the representatives of civil society monitored the progress of the evaluation and 
provided comments and feedback to ensure the quality and objectivity of the report. Both 
meetings were held in hybrid format.  

Survey with the private sector and civil society organisations 

The  survey  was  part  of  the  study’s  consultation  process.  Two  different  surveys  of 
approximately  20  questions  targeting  civil  society  and  private  sector  organisations 
respectively  were  designed.  The  questions  were  for  the  most  part  single  and  multiple-
choice with predefined response options, thereby facilitating completion. 

Given  the  range  of  different  types  of  actions  that  have  to  be  examined  and  evaluated, 
specific questions were designed for the two different set of stakeholders. However, all 
questions  focused  on  horizontal  and  comparable  issues  in  the  specific  criteria  such  as 
effectiveness, efficiency, and relevance.  

The  majority  of  the  questions  included  in  the  survey  were  multiple-choice  questions, 
asking the participant to assign a score based on a Likert scale. The purpose of this set-up 
is to ensure participants do not need to spend more than 15 minutes answering the survey, 
as  it  is  known  that  lengthy  surveys  tend  to  discourage  participation.  At  the  same  time, 
however,  a  number  of  voluntary  open  questions  were  also  included,  allowing  those 
participants that are willing and interested in providing more information to do so. 

The survey addressing CSOs included an assessment of the role of the EU trade agreement 
across  the  cross-cutting  priorities  of  the  study  (MEA  Ratification  and  compliance, 
regulatory  cooperation,  non-regression,  alliance  building,  green/climate  friendly 
technologies)  and  some  key  issues  (deforestation,  biodiversity  protection,  circular 
economy). The survey directed to the private sector was focused on assessing the impact 
of the agreement’s environmental provisions on their business. 

The  survey  remained  online  for  a  duration  of  4  weeks,  allowing  ample  opportunity  for 
stakeholders to participate. It was facilitated through the EU Survey platform and accessed 
via two primary channels: 

•  The consortium leader’s LinkedIn account; and 
•  European  Commission  networks:  X  (previously  known  as  Twitter)  and  the  DG 

TRADE newsletter. 

Furthermore, the survey was circulated among key stakeholders, including selected trade 
associations  involved  in  the  consultation  process,  who  distributed  the  link  among  their 
members  and  shared  it  on  their  social  media  platforms.  A  total  of  15  stakeholders 

53 

 
responded  to  the  questionnaire  for  CSOs.  A  total  of  9  stakeholders  responded  to  the 
questionnaire for the private sector. 

To  adhere  to  EU  GDPR  regulations,  the  survey  included  a  privacy  statement  and  was 
designed to maintain respondent anonymity. 

AIV.2 Summary of stakeholders’ contributions  

In  what  follows,  the  views  and  contributions  of  stakeholders  are  summarised.  Overall, 
public sector stakeholders across the EU and partner countries were positive with regard 
to  the  role  of  EU  agreements  in  promoting  regulatory  cooperation  and  maintaining 
the 
environmental  commitments,  with  virtually  all  stakeholders  stressing 
implementing  factors  of  the  agreements  provide  important  avenues  for  dialogue  and 
information exchange. Public sector stakeholders in developing economies also stressed 
the  importance  of  the  nexus  between  regulatory  cooperation  activities  and  technical 
assistances, with several examples being raised with regard to assistance being provided 
for environmental legislation and/or policy.  

that 

However, while being  positive with  regard to  the Agreements’ TSD Chapters and their 
implementing  factors,  public  sector  stakeholders,  stressed  that  the  environmental 
provisions EU FTAs are only of the instruments that the EU can and does use to facilitate 
dialogue on environmental policy issues, and that they work in synergy with other forms 
of  political  and  technical  dialogue,  as  well  as  with  other  agreements  and  cooperation 
frameworks, such as, for example, the Green Alliances and Partnerships.  

to 

Civil  society  stakeholders,  including  academic  experts,  in  both  the  EU  and  partner 
countries provided a somewhat more mixed picture, as there seems to be a general view 
that  relative 
labour  provisions,  environmental  provisions  only  entail  broad 
commitments,  and  as  such  they  do  not  always  provide  sufficient  instruments  for 
monitoring. Stakeholders at the European Commission appear to broadly agree with this 
sentiment,  although  they  also  highlight  that  the  recent  introduction  of  the  Single  Entry 
Point  (SEP)  and  the  inclusion,  since  the  beginning  of  the  TSD  approach,  of  stringent 
clauses against regression, can at least partly overcome some of the issues with monitoring 
and enforcement.  

Finally, private sector stakeholders also paint a mixed picture. On the one hand, there is 
broad recognition of the opportunities that the agreements open up in terms of greater trade 
in  environmental  goods  and  services  and  the  possibility  for  technology  transfer;  on  the 
other,  several  private  sector  stakeholders  expressed  apprehension  with  regard  to  the 
possible additional costs that environmental standards may impose on business. However, 
it  is  important  to  stress  that  this  apprehension  appears  to  stem  primarily  from  recent 
discussions around the autonomous measures including the EUDR and CBAM, rather than 
from the environmental clauses of the agreements specifically.  

Stakeholders’ views on effectiveness, efficiency, and coherence  

54 

 
With  regard  to  the  ratification  and  compliance  with  MEAs,  stakeholders  in  partner 
countries  ranging  from  Georgia  to  Colombia  expressed,  in  general,  positive  statements 
with regard to the alignment between their own domestic environmental policies and the 
environmental  policy  priorities  specified  in  EU  FTAs.  At  least  one  public  sector 
stakeholder in Viet Nam went one step forward, and expressed the view that the EVFTA 
has supported the country increase its level of ambition in environmental policy-making.  

Stakeholders in countries including Costa Rica, Canada, Singapore, and Japan, particularly 
in  the  public  sector,  express  the  view  that  their  countries  and  the  EU  are  like-minded 
partners  and  that  the  FTAs,  together  with  other  agreements  and  political  as  well  as 
technical  dialogues,  can  open  platforms to  pursue common objectives in  environmental 
policy. In these countries, there is a view that environmental policy-making, particularly 
with regards to MEAs, is just as advanced as it is in the EU, and that the implementing 
factors of the Agreements are useful to promote dialogue and information exchange.  

In  some  countries,  particularly  developing  economies,  such  as  Georgia  and  Viet  Nam 
among  others,  stakeholders  indicated  satisfaction  with  the  level  of  technical  support 
received  by  individual  EU  Member  States  and  other  international  donors  in  drafting 
specific environmental legislation and policies that can support greater compliance with 
the MEAs listed in each Agreement. Costa Rica is another country in which stakeholders 
discussed  how  regulatory  cooperation  and  technical  assistance  from  the  EU  and  its 
Member  States  was  linked  to  positive  developments  in  environmental  legislation  and 
policy. 

The interviews yielded several insightful details and stakeholder opinions with regard to 
regulatory cooperation. Among the examples mentioned, there is cooperation leading to 
the  VPA-FLEGT  in  Viet  Nam  and  Honduras.  In  Viet  Nam,  stakeholders  from  the  EU 
pointed to progress and cooperation in a wide range of environmental policy issues ranging 
from  the  circular  economy  to  plastics  recycling  and  wildlife  trafficking.  In  Peru, 
stakeholders pointed to recent dialogues in the context of the circular economy, leading to 
roadmaps to support policy-makers in the formulation of policies promoting more circular 
practices. In the Republic of Korea, cooperation activities are starting with regards to the 
modernisation of the country’s ETS, with study tours and the exchange of experts. In Costa 
Rica, stakeholders mentioned, among other examples of regulatory cooperation leading to 
legislative outcomes, the example of the Circular Economy Law of 2019, resulting from 
technical  support  from,  and  cooperation  with  the  EU  and  specific  Member  States.  In 
another important example, stakeholders in both the EU and Japan praised technical and 
regulatory  cooperation  between  the  two  parties  to  facilitate  trade  in  the  offshore  wind 
sector,  even  though  this  took  place  primarily  through  the  Regulatory  Cooperation 
Committee established by the EPA rather than the TSD Committee specifically.  

It is important to stress that in several other instances, the stakeholders interviewed for the 
evaluation referred to cooperation with the EU more generally rather than cooperation as 
promoted under the Agreement or its TSD Chapter specifically. For example, in the case 
of  Canada,  CETA  and  the  Strategic  Partnership  Agreement  (SPA)  both  serve  as 

55 

 
frameworks  for  regulatory  cooperation  between 
the  parties.  Additionally,  and 
interestingly,  public  sector  stakeholders  in  Costa  Rica  acknowledged  the  role  of  the 
country as a hub for regulatory cooperation and technical assistance between the EU and 
the wider Central American region.  

There  appears  to  be  a  consensus  that  when  it  comes  to  regulatory  cooperation,  the 
Agreements  do  provide  the  EU  with  an  additional  platform  to  engage  in  dialogue  on 
environmental  policy  aspects  with  partner  countries,  which  is  accompanied  by  greater 
focus and priority. At the same time, stakeholders also acknowledge that the majority of 
the  discussions  in  the  past  two  years  has  started  revolving  around  the  autonomous 
measures. While there is overlap between these and the contents of the TSD Chapters, the 
discussion is moving away from the Chapters.  

Among virtually all stakeholders in both the EU and partner countries, there was consensus 
that non-regression clauses are perceived as very useful to help partner countries stick to 
their  own  environmental  policy  baselines.  There  was  a  general  consensus  on  this  point 
among experts and EU Commission officials at different DGs and the EUDs. At least one 
stakeholder reported that this is because non-regression clauses are the only “prescriptive” 
and  “strict”  environmental  provision  in  EU  FTAs.  At  the  same  time,  however,  EU 
stakeholders who are knowledgeable of environmental policy in Peru expressed cautious 
concerns around a recent amendment to the 2011 forest law, a development which they say 
should continue being monitored.  

With  regard  to  trade  in  EGS,  both  private  and  public  sector  stakeholders  expressed 
satisfaction with the market access ensured by the Agreements and with the possibilities 
that trade in environmental goods may open for technology diffusion, with one stakeholder 
in Japan expressing a positive view of EU-Japan regulatory cooperation in the offshore 
wind sector. Stakeholders in Canada, in another example, emphasised a number of joint 
initiatives and investments in lithium-ion battery manufacturing. Stakeholders in Georgia 
pointed  to  the  importance  of  business  missions  facilitated  by  the  EU  to  help  Georgian 
businesses  gain  exposure  to  technological  development  and  trade  opportunities.  In 
Georgia,  several  stakeholders  also  noted  initiatives  and  programmes  aimed  at  the 
technological upgrading of the timber sector to ensure greater sustainability.  

When it comes to alliance building, stakeholders in both Canada, Japan, and the EU spoke 
positively of the recently introduced Green Alliances to foster dialogue and cooperation in 
several important areas of common interest, ranging from the manufacturing of net-zero 
technologies  such  as  carbon  capture,  batteries,  and  green  hydrogen;  to  issues  of 
biodiversity  and  the  circular  economy.  Stakeholders  from  the  public  sector  in  Georgia 
spoke positively on recent international initiatives in waste management, which, they said, 
can reinforce efforts to support compliance with MEAs. Canadian stakeholders reported 
that  Canada  is  actively  pursuing  collective  action  through  multilateral  fora  on  critical 
minerals issues to support the global energy transition, more resilient supply chains, and 
more sustainable and responsible sourcing practices. 

56 

 
With regard to the implementing factors of the EU FTAs, and particularly the DAGs, 
both public sector and civil society stakeholders in the EU and partner countries concur 
that  the  DAGs  are  a  useful  platform  for  civil  society  to  voice  their  concerns.  Several 
stakeholders acknowledge that there is a trade-off between efficiency and inclusiveness in 
the  DAGs:  the  current  combination  of  smaller  DAGs  and  larger  civil  society  fora  and 
dialogues is regarded as a good compromise.  

While the DAGs are regarded positively, there is also consensus, particularly among civil 
society stakeholders, that the functioning and effectiveness of DAGs can be improved. One 
area  for  improvement  that  was  mentioned  frequently  is  that  the  DAGs  can  sometimes 
function more as spaces for the Commission to provide information unilaterally to civil 
society  while,  on  the  other  hand,  civil  society  organisations  tend  to  use  the  DAGs  for 
advocacy  on  specific  issues  rather  than  as  fora  for  dialogue  and  monitoring  of  the 
agreements. A related issue mentioned by at least two stakeholders who participate in the 
EU DAGs is that information flow is not always optimal, with DAG members not having 
access to the minutes of TSD Committee meetings or to information that is not already 
publicly available.  

Civil society stakeholders also pointed to the fact that the DAGs, at least according to their 
original formulation, should act as watchdogs, enabling the monitoring of the agreements’ 
TSD  Chapters.  However,  since  key  performance  indicators  (KPIs),  targets,  work-plans, 
and  roadmaps  are  not  widely  utilised,  the  DAGs  do  not  function  as  outcome-oriented 
forums.  Two  stakeholders  suggested  that  as  a  practical  idea,  the  DAGs  could  be 
empowered  to  design  roadmaps,  allowing  civil  society  stakeholders  to  identify  priority 
areas that they would want to work on and include concrete measures and follow-up actions 
that  could  be  pursued  Finally,  some  civil  society  stakeholders  suggested  that  since  the 
membership of the DAGs is very wide, it may be useful to subdivide discussions according 
to specific sectors or knowledge groups, for the discussions to be more specific.  

Civil society respondents to the survey echoed these sentiments, expressing that the DAGs 
have the potential to monitor the agreements’ implementation o the ground, but that this 
potential is not fully expressed at the moment.  

In addition, in some of the partner countries studied for this evaluation, the functioning of 
the local DAGs can be affected by external factors that are outside of the EU’s control. 
These  factors  include  the  shrinking  of  civil  space  in  Viet  Nam,  which  was  stressed  by 
several stakeholders with knowledge of the country in the EU. Stakeholders in both the 
EU  and  Japan  also  pointed  to  the  role  of  the  Ministry  for  Foreign  Affairs  in  Japan  in 
selecting  environmental  organisations  that  can  participate.  One  academic  researcher  in 
Japan expressed the view that Japanese environmental civil society organisations may not 
yet be using the agreement to the fullest extent.  

With regard to the TSD Committee, stakeholders at the EU Commission tend to be of the 
opinion that the TSD Committee is an effective forum for bilateral dialogue. This view is 
broadly  echoed  by  their  counterparts  working  in  the  public  administration  of  partner 

57 

 
countries. However, some stakeholders at the Commission perceive that the once-a-year 
meeting format can reduce the scope for dialogue. While it is too costly to hold meetings 
more than once a year, other forms of ongoing dialogue are said to be welcome. One public 
sector stakeholder in Singapore further indicated that the TSD Committee is particularly 
useful  for  parties  to  clarify  their  respective  positions  and  improve  mutual  trust  and 
understanding,  particularly  at  times  where  the  EU  introduces  new  environmental 
legislation.  

With regard to the efficiency of the agreements, among public sector stakeholders in the 
EU  there  is  a  consensus  that  the  benefits  of  the  EU  agreements  in  terms  of  dialogue, 
information exchange, and trust-building with partner countries on environmental policies 
and priorities clearly outweigh any administrative costs associated with the Agreements’ 
implementing factors.  

With regard to the distribution of costs and benefits, both private sector stakeholders and 
academic experts in countries including, among others, Costa Rica, Georgia, Ecuador, Viet 
Nam,  and  Japan,  pointed  to  businesses  facing  costs  to  comply  with  EU  environmental 
standards. In Viet Nam, public sector stakeholders report of issues with compliance with 
REACH and the  Restricted Substances List (RSL)  in  the textile and garment  sector.  In 
Costa Rica and Honduras, concerns arose around the EUDR. However, the vast majority 
of  these  concerns  do  not  arise  specifically  from  the  environmental  provisions  in  EU 
agreements.  In  addition,  several  interviewees,  including  in  Viet  Nam  and  Colombia, 
expressed the view that local firms have increased their awareness of, and compliance with, 
environmental regulations thanks to their exposure to the EU market, with positive knock-
on  effects  on  their  export  competitiveness.  Technical  assistance  for  improvements  in 
agricultural  and  manufacturing  practices  in  Ecuador  is  acknowledged  by  industry 
associations. 

Among  private  sector  respondents  to  the  survey,  all  of  whom  are  EU-based,  some 
expressed concerns around competition from third-country producers who may not meet 
the  same  sustainability  standards,  with  concerns  around,  for  example,  the  reliability  of 
labelling  from  third-country  products.  However,  more  generally,  most  private  sector 
stakeholders express the recognition that heightened sustainability ambitions could foster 
trade  and  investment  prospects  for  green  goods  and  clean  technologies  and  services. 
Specific  opportunities  mentioned  include  consulting  services  in  the  green  sector  and 
support mechanisms for companies, reflecting an increasing appreciation for EU-produced 
clean technology. 

Finally, with regard to coherence, the general consensus among stakeholders at the EU 
Commission is that the environmental provisions in EU agreements work in synergy both 
with EU environmental policies and priorities such as the European Green Deal and with 
global environmental policy priorities such as the SDGs. The environmental provisions 
and TSD Chapters are often described as part of a thick network of agreements, dialogues, 
initiatives,  and  projects  that  the  EU  and  its  Member  States  carry  forward  with  partner 
countries.  One  area  of  concern  that  was  mentioned  by  both  civil  society  stakeholders, 

58 

 
including academic experts, and stakeholders at the EU Commission is that environmental 
provisions are not specific enough. The labour provisions, by contrast, are widely regarded 
as more specific. According to stakeholders, this means that the EU has less margin for 
manoeuvre with partners. At the time at which the consultations take place, the SEP had 
only been used for labour matters and there were no examples of SEP complaints around 
environmental issues.29  

Stakeholders’ views on relevance  

In addition to the caveat that the environmental provisions in EU agreements are widely 
regarded as being too broad or not prescriptive enough—an opinion that is shared across 
stakeholder  groups,  including  civil  society  and  public  administration  in  the  EU—there 
seems to be debate around the relevance of the agreements among stakeholders. There is 
agreement  that  the  environmental  provisions  are  relevant,  and  that  with  each  new 
agreement that the EU signs with partners, the TSD approach becomes more sophisticated. 
However, some stakeholders at the Commission expressed the view that the Agreements 
could be modernised, including with regard to dispute settlement and to the inclusion of 
either new MEAs that are coming to the fore, such as the Kunming-Montreal agreement; 
or  new  provisions  that  are  not  necessarily  linked  to  MEAs  but  that  are  nonetheless 
important,  such  as  provisions  stipulating  the  protection  of  forests,  marine  biology,  and 
biodiversity.  

Other  stakeholders  are  of  the  opinion  that  modernisation  is  not  needed,  because  the 
implementing factors of the agreements allow parties to  raise, discuss, and solve issues 
related to environmental policy and protection regardless of whether these are explicitly 
stipulated in an agreement. They also point to the difficulties of modernising an agreement, 
with long negotiating time and uncertainty around political priorities. An example that is 
often raised by stakeholders at the Commission as well as by civil society stakeholders 
who  participate  to  the  EU  DAGs  and  civil  society  engagements  is  that  the  unilateral, 
autonomous measures have “hijacked” the discussions with partners. This occurs in the 
TSD Committee but also in other Committees. One stakeholder reported that the Andean 
countries  wanted  to  discuss  deforestation  at  all  Committees  (including  trade  in  goods) 
including the TSD committee.  

29 The evaluation team was subsequently informed that there is one environmental complaint that has been 

raised in the SEP.  

59