Sittings · Document

DRAFT OPINION (2024/2108(INI)) 2025-05-02

On the implementation of the EU-UK Trade and Cooperation Agreement

Committee on the Environment, Climate and Food Safety · Rapporteur: Sander Smit

AMENDMENTS

The Committee on the Environment, Climate and Food Safety submits the following to the Committee on Foreign Affairs and the Committee on International Trade, as the committees responsible:

Amendment 1

Motion for a resolution

Citation 10 a (new)

Motion for a resolution	Amendment
	– having regard to the minutes of the third meeting of the Trade and Cooperation Agreement Partnership Council of 16 May 2024,

Or. en

Amendment 2

Motion for a resolution

Citation 10 b (new)

Motion for a resolution	Amendment
	– having regard to the minutes of the fifth meeting of the Specialised Committee on Energy in London on 7 November 2024,

Or. en

Amendment 3

Motion for a resolution

Citation 10 c (new)

Motion for a resolution	Amendment
	– having regard to the minutes of the fourth meeting of the Trade Specialised Committee on Technical Barriers to Trade in Brussels on 7 October 2024,

Or. en

Amendment 4

Motion for a resolution

Citation 10 d (new)

Motion for a resolution	Amendment
	– having regard to the minutes of the fourth meeting of the Trade Specialised Committee on Sanitary and Phytosanitary Measures under the EU-UK Trade and Cooperation Agreement on 21 October 2024,

Or. en

Amendment 5

Motion for a resolution

Citation 10 e (new)

Motion for a resolution	Amendment
	– having regard to the minutes of the fourth meeting of the Trade Specialised Committee on Level Playing Field for Open and Fair Competition and Sustainable Development under the EU-UK Trade and Cooperation Agreement of 9 October 2024,

Or. en

Amendment 6

Motion for a resolution

Citation 10 f (new)

Motion for a resolution	Amendment
	– having regard to the joint statement of the EU and UK Domestic Advisory Groups (DAGs) of 19 September 2024,

Or. en

Amendment 7

Motion for a resolution

Citation 10 g (new)

Motion for a resolution	Amendment
	– having regard to the conclusions of the third Civil Society Forum of the UK-EU Trade and Cooperation Agreement of 20 September 2024,

Or. en

Amendment 8

Motion for a resolution

Citation 10 h (new)

Motion for a resolution	Amendment
	– having regard to the House of Commons Library research briefing of 5 March 2025 entitled ‘Resetting the UK’s relationship with the European Union’,

Or. en

Amendment 9

Motion for a resolution

Recital A a (new)

Motion for a resolution	Amendment
	Aa. whereas the EU and the UK face a shared set of global challenges owing to geopolitical instability, including safeguarding food security and affordability, and reducing energy dependencies and supply chain vulnerabilities; whereas the EU and the UK also share common ambitions in the fields of climate change mitigation, environmental protection and food safety;

Or. en

Amendment 10

Motion for a resolution

Recital D a (new)

Motion for a resolution	Amendment
	Da. whereas there is a growing risk of regulatory divergence between the EU and the UK in the fields of the environment, climate policy and food safety; whereas such divergence could cause economic disruption and undermine the effectiveness of environmental and climate action, in particular in the context of Northern Ireland and the Republic of Ireland;

Or. en

Amendment 11

Motion for a resolution

Recital I a (new)

Motion for a resolution	Amendment
	Ia. whereas the UK Government has called for a ‘reset’ in EU-UK relations, aiming to enhance strategic cooperation and alignment in the fields of the environment, climate policy and food safety in order to reduce trade frictions in recognition of the shared geopolitical challenges and mutual ambitions regarding climate and environmental matters;

Or. en

Amendment 12

Motion for a resolution

Recital P a (new)

Motion for a resolution	Amendment
	Pa. whereas in 2023, the UK raised concerns regarding EU market interventions under the Green Deal Industrial Plan; whereas the EU has announced further interventions, for example under the Clean Industrial Deal, which may raise similar concerns;

Or. en

Amendment 13

Motion for a resolution

Recital P b (new)

Motion for a resolution	Amendment
	Pb. whereas the non-regression clause under Article 391(4) of the TCA prohibits both parties from lowering environmental and climate targets in ways that affect trade or investment; whereas although this provision safeguards adherence to high standards, it may also give rise to legal uncertainty and litigation risks in the light of the EU’s regulatory simplification agenda;

Or. en

Amendment 14

Motion for a resolution

Recital Q a (new)

Motion for a resolution	Amendment
	Qa. whereas both the EU and UK DAGs have called for a strengthened role for civil society stakeholders in monitoring and advising on trade and sustainable development commitments under the EU-UK TCA;

Or. en

Amendment 15

Motion for a resolution

Recital Q b (new)

Motion for a resolution	Amendment
	Qb. whereas the UK Government has expressed its willingness to enter into negotiations with the EU on a comprehensive Sanitary and Phytosanitary (SPS) agreement, including the possibility of a veterinary agreement, with the aim of reducing barriers in agri-food trade and facilitating the smoother movement of animal and plant products;

Or. en

Amendment 16

Motion for a resolution

Subheading 8

Motion for a resolution	Amendment
Environment and climate	Environment

Or. en

Amendment 17

Motion for a resolution

Paragraph 25 (after subheading 8 ‘Environment’)

Motion for a resolution	Amendment
25. [opinion-giving committees];	25. Highlights the increasing risk of regulatory divergence between the EU and the UK in environmental policy, potentially leading to economic disruption and undermining the impact of environmental and climate policies; calls for current structures to be enhanced to foster dialogue and cooperation in order to mitigate the economic disruptions caused by regulatory divergence, while enhancing the effectiveness of environmental and climate policies;

Or. en

Amendment 18

Motion for a resolution

Paragraph 25 a (new)

Motion for a resolution	Amendment
	25a. Recalls the particular situation of Northern Ireland, where environmental regulation is now diverging from the EU’s legislative framework; recognises the shared environment on the island of Ireland and stresses that pollution knows no borders; highlights, in this respect, how developments in British environmental policies impact the environment on the entire island of Ireland and therewith the achievement of the EU’s environmental protection goals;

Or. en

Amendment 19

Motion for a resolution

Paragraph 25 b (new)

Motion for a resolution	Amendment
	25b. Recalls the joint statement of the EU and UK DAGs on maintaining regulatory cooperation on chemicals; notes that the UK has highlighted opportunities for closer bilateral collaboration in this area; recommends aligning with the UK in the upcoming revision of the REACH Regulation1a to promote cooperation and convergence in order to avoid further regulatory divergence; ______________ 1a Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18 December 2006 concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), OJ L 396, 30.12.2006, p. 1, ELI: http://data.europa.eu/eli/reg/2006/1907/oj.

Or. en

Amendment 20

Motion for a resolution

Paragraph 25 c (new)

Motion for a resolution	Amendment
	25c. Welcomes the UK’s recognition of the CE marking regarding eco-design requirements on energy-related products and restrictions on hazardous substances in electrical and electronic equipment; welcomes the fact that this facilitates continued trade between the UK and the EU, while reducing compliance burdens for manufacturers;

Or. en

Amendment 21

Motion for a resolution

Paragraph 25 d (new)

Motion for a resolution	Amendment
	25d. Recalls that both the EU and the UK have committed under the TCA to maintain high levels of environmental protection, including in the areas of waste management and the circular economy; stresses the importance of using this momentum to launch a pan-European circular economy agenda by securing lower primary and virgin resource and material use, the production and consumption of durable and repairable products and of products with recycled content, and sufficient waste treatment capacity in the EU and the North Sea region in order to enable viable business models for secondary raw materials through recycling, while reducing resource dependency;

Or. en

Amendment 22

Motion for a resolution

Paragraph 25 e (new)

Motion for a resolution	Amendment
	25e. Recalls the necessity of fully implementing the waste hierarchy as part of the upcoming Circular Economy Act; recalls the necessity of waste-to-energy facilities and applications for treating residual streams from recycling processes, particularly in north-western Europe, as part of the upcoming Circular Economy Act;

Or. en

Amendment 23

Motion for a resolution

Paragraph 25 f (new)

Motion for a resolution	Amendment
	25f. Stresses the importance of close coordination on the potential inclusion of the waste sector in the EU Emissions Trading System (ETS) from 2028 onwards, to safeguard and enhance pan-European cooperation on the circular economy, with a focus on waste-to-energy solutions, including biogas, green gas, e-fuels and other alternative feedstocks;

Or. en

Amendment 24

Motion for a resolution

Paragraph 25 g (new)

Motion for a resolution	Amendment
	25g. Notes, with concern, the lack of coordination between national climate and environmental goals and waste management capacities and technologies; stresses that both the UK and the EU should better plan and adapt their waste management infrastructure; calls for a holistic approach that, for example, recognises the emission reduction potential of waste-to-energy solutions as part of broader climate and circular economy strategies;

Or. en

Amendment 25

Motion for a resolution

Paragraph 25 h (new)

Motion for a resolution	Amendment
	25h. Recognises that large-scale sustainable energy projects, such as offshore wind farms, may conflict with the conservation objectives of Natura2000 sites and marine protected areas, potentially destroying seabeds and impacting fishing grounds; calls for further EU-UK cooperation on research to assess these impacts and develop strategies that balance environmental conservation with coastal or marine sustainable energy generation, including nuclear energy;

Or. en

Amendment 26

Motion for a resolution

Paragraph 25 i (new)

Motion for a resolution	Amendment
	25i. Underlines the importance of maintaining co-use access for sustainable fisheries in areas with offshore wind farms to balance environmental, economic and food security priorities; recognises that in the current geopolitical context, sustainable fisheries and aquaculture form a low-carbon contribution to food security;

Or. en

Amendment 27

Motion for a resolution

Paragraph 25 j (new)

Motion for a resolution	Amendment
	25j. Expresses concern over the inequality in legal treatment of the fisheries sector compared to sustainable energy projects in EU-UK waters, such as offshore wind farms, with regard to their environmental impact; calls for a balanced approach that weighs climate objectives against broader societal and environmental interests, ensuring consistency and fairness across sectors;

Or. en

Amendment 28

Motion for a resolution

Paragraph 25 k (new)

Motion for a resolution	Amendment
	25k. Calls for a strengthened role for civil society stakeholders in the monitoring and advisory processes related to trade and sustainable development commitments under the EU-UK TCA in relation to environmental and climate policies, in line with the joint statement of the EU and UK DAGs;

Or. en

Amendment 29

Motion for a resolution

Paragraph 25 l (new)

Motion for a resolution	Amendment
	25l. Notes that the UK has raised concerns regarding EU market interventions under the Green Deal Industrial Plan; notes that the EU has announced further interventions, for example under the Clean Industrial Deal, which may raise similar concerns; calls for close coordination to prevent protectionist measures that could hinder trade and undermine mutual trust and legal certainty for market participants;

Or. en

Amendment 30

Motion for a resolution

Paragraph 25 m (new)

Motion for a resolution	Amendment
	25m. Notes that the UK has rapidly phased out direct income support for farmers and replaced it with biodiversity and climate-related schemes; notes, in particular, that many small and family-run farms have faced insufficient security because of these policy shifts, leading to a steep decline in the number of family-run farms in the UK; underlines the potential impacts of this on trade and long-term European food security;

Or. en

Amendment 31

Motion for a resolution

Subheading 8 a (new) (after Paragraph 25 m (new))

Motion for a resolution	Amendment
	Climate

Or. en

Amendment 32

Motion for a resolution

Paragraph 25 n (new) (after subheading ‘Climate’)

Motion for a resolution	Amendment
	25n. Notes that both the EU and the UK maintain high ambitions on reducing CO2 emissions and global leadership on climate protection; notes that the UK’s 2035 Nationally Determined Contribution (NDC) target, announced at COP29 in November 2024, is to reduce all greenhouse gas emissions by at least 81 % compared to 1990 levels, surpassing the EU’s 2030 target of a 55 % reduction;

Or. en

Amendment 33

Motion for a resolution

Paragraph 25 o (new)

Motion for a resolution	Amendment
	25o Notes that the TCA obliges both parties to maintain an effective carbon pricing system; notes that the UK introduced its own ETS in May 2021, which closely resembles the EU ETS; highlights that the UK’s ETS is beginning to show growing divergence regarding the rate of cap reduction, coverage and carbon pricing;

Or. en

Amendment 34

Motion for a resolution

Paragraph 25 p (new)

Motion for a resolution	Amendment
	25p. Notes that the TCA requires both parties to ‘give serious consideration’ to linking their carbon pricing systems to allow for mutual recognition of allowances and to reduce unnecessary trade barriers; notes that the UK Government is actively considering linking the UK ETS to the EU ETS; stresses that such linkage should be undertaken without undermining the integrity and effectiveness of the EU ETS; highlights that the linkage between the EU ETS and the Swiss ETS took over a decade to conclude; urges, therefore, the immediate commencement of negotiations to avoid similar delays and to foster regulatory alignment and market stability;

Or. en

Amendment 35

Motion for a resolution

Paragraph 25 q (new)

Motion for a resolution	Amendment
	25q. Notes that informal Council discussions in December 2024 revealed a general openness among EU Member States to an agreement with the UK on linking the two ETSs, contingent on full dynamic alignment with the Union acquis and the continued jurisdiction of the Court of Justice of the European Union over the interpretation of the applicable legislation in both the EU and the UK;

Or. en

Amendment 36

Motion for a resolution

Paragraph 25 r (new)

Motion for a resolution	Amendment
	25r. Notes that, in the absence of alignment, UK exports to the EU may be subject to EU Carbon Border Adjustment Mechanism levies once the mechanism becomes fully operational in 2026; notes, with concern, the potential economic and political impact of this on Northern Ireland, as well as the impact on critical supply chains for the development of clean technologies;

Or. en

Amendment 37

Motion for a resolution

Paragraph 25 s (new)

Motion for a resolution	Amendment
	25s. Notes that the EU and the UK agree that carbon capture utilisation and storage (CCUS) is important for reaching ‘net zero’; notes the UK’s commitment to UK-EU cooperation on this new technology; recommends using the Specialised Committee on Energy to deepen cooperation on CCUS technologies, including cross-border storage of CO₂ emissions;

Or. en

Amendment 38

Motion for a resolution

Paragraph 25 t (new)

Motion for a resolution	Amendment
	25t. Notes that the initial rules of origin for electric vehicles under the TCA, set to apply from 2024 and aimed at supporting CO₂ emission reductions, have proven difficult to comply with in practice; welcomes the agreement between the EU and the UK to extend the current rules until the end of 2026, thereby avoiding the reintroduction of tariffs, limiting cost increases for consumers and reducing the risk of production disruptions; supports the joint calls from EU and UK battery manufacturers for stronger supply chain integration;

Or. en

Amendment 39

Motion for a resolution

Paragraph 25 u (new)

Motion for a resolution	Amendment
	25u. Stresses the strategic importance of reliable access to critical raw materials for the green transition; encourages the coordination of trade positions and joint action to diversify supply chains, reduce dependency on dominant suppliers and promote sustainable sourcing and the efficient use and reuse of critical materials; calls for enhanced bilateral cooperation, including through a potential UK-EU partnership on critical minerals;

Or. en

Amendment 40

Motion for a resolution

Paragraph 26 (after subheading ‘Food safety’)

Motion for a resolution	Amendment
26. [opinion-giving committees];	26. Notes that the SPS provisions under the TCA build on the obligations of the EU and the UK under the World Trade Organization’s (WTO) SPS Agreement, aiming to mitigate SPS-related trade frictions by reducing controls on food and feed products;

Or. en

Amendment 41

Motion for a resolution

Paragraph 26 a (new)

Motion for a resolution	Amendment
	26a. Notes that Council discussions in December 2024 indicated EU Member States’ openness to an agreement with the UK on removing the SPS border, provided there is full alignment with the Union acquis and the continued jurisdiction of the Court of Justice of the European Union over the interpretation of the applicable legislation in both the EU and the UK;

Or. en

Amendment 42

Motion for a resolution

Paragraph 26 b (new)

Motion for a resolution	Amendment
	26b. Recalls that the UK’s Border Target Operating Model, activated on 30 April 2024, has resulted in substantial disruption to trade; encourages the UK to establish a formal notification protocol by the end of 2025, aligning it with the WTO’s SPS obligations so as to enhance trade predictability and reduce disruptions;

Or. en

Amendment 43

Motion for a resolution

Paragraph 26 c (new)

Motion for a resolution	Amendment
	26c. Notes that between 2022 and 2024, the EU lowered the maximum residue levels for 49 pesticides, including 15 classified as highly hazardous; emphasises the potential implications of such regulatory divergence for consumer safety, environmental protection and the level playing field in agri-food trade and for primary producers in the EU;

Or. en

Amendment 44

Motion for a resolution

Paragraph 26 d (new)

Motion for a resolution	Amendment
	26d. Notes that diverging per- and polyfluoroalkyl substance (PFAS) thresholds between the EU and the UK risk trade distortions and consumer confusion; calls for closer cooperation between the European Food Safety Authority (EFSA) and the competent UK authority on monitoring and risk assessment; recommends aligning PFAS limits in food and feed to safeguard public health and ensure fair trade;

Or. en

Amendment 45

Motion for a resolution

Paragraph 26 e (new)

Motion for a resolution	Amendment
	26e. Acknowledges the Genetic Technology (Precision Breeding) Act that became law in England on 23 March 2023, which revises the rules for the release and marketing of, and risk assessments related to, gene-edited, precision-bred plants and animals, by exempting them from the regulatory requirements – including labelling – that apply to genetically modified organisms; is concerned about regulatory divergence in this area and of continuing uncertainties relating to the legal status and flow of ‘precision-bred’ crops and food products between Northern Ireland and the EU;

Or. en

Amendment 46

Motion for a resolution

Paragraph 26 f (new)

Motion for a resolution	Amendment
	26f. Stresses the need to maintain strong SPS controls at the EU’s borders, as fully provided for under EU law, to ensure that unauthorised products or those without proper labelling cannot enter the EU food chain; stresses, furthermore, the need for a level playing field and fair competition for EU producers and consumers in this regard;

Or. en

Amendment 47

Motion for a resolution

Paragraph 26 g (new)

Motion for a resolution	Amendment
	26g. Notes that the UK proposed establishing technical discussions on antimicrobial resistance under the framework of the TCA; regrets that the EU expressed its preference that such discussions remain ad hoc and calls for increased cooperation;

Or. en

Amendment 48

Motion for a resolution

Paragraph 26 h (new)

Motion for a resolution	Amendment
	26h. Welcomes the UK Government’s commitment to enter into negotiations with the EU on a comprehensive SPS agreement with a view to reducing barriers in agri-food trade; calls for deepened cooperation between the EFSA and the respective UK agencies;

Or. en

Amendment 49

Motion for a resolution

Paragraph 26 i (new)

Motion for a resolution	Amendment
	26i. Calls on the Commission to prioritise negotiating a comprehensive SPS agreement with the UK by mid-2026, as part of a broader strategy to proactively monitor and address policy divergences with the EU, urging prompt action to enhance trade stability and regulatory alignment;

Or. en

Amendment 50

Motion for a resolution

Paragraph 26 j (new)

Motion for a resolution	Amendment
	26j. Calls on the Commission to prioritise negotiating a comprehensive veterinary agreement with the UK as a central component of the broader SPS agreement; stresses the importance of aligning animal health and welfare standards in order to safeguard biosecurity, while preserving a level playing field;

Or. en

Amendment 51

Motion for a resolution

Paragraph 26 k (new)

Motion for a resolution	Amendment
	26k. Calls on the Commission to resolve the procedural hurdles regarding non-commercial movements of pet animals;

Or. en

ANNEX: ENTITIES OR PERSONS FROM WHOM THE RAPPORTEUR HAS RECEIVED INPUT

The rapporteur for the opinion declares under his exclusive responsibility that he did not receive input from any entity or person to be mentioned in this Annex pursuant to Article 8 of Annex I to the Rules of Procedure.