Does the EU enforce the green standards it exports?

Jul 27, 2026
Does the EU enforce the green standards it exports? COMMENTARY
Photo credits: EPC via Canva
Michele Galli
Adviser, EU and Global Sustainable Development

The EU sets high green standards but too often fails to enforce them — weakening them under pressure and leaving them unenforceable beyond its borders. Its multilateral credibility depends on closing that gap. 

The EU's multilateral influence has long rested on a tacit bargain: it sets standards, promotes rules, and asks others to follow. Nowhere is this more visible than in sustainability ambitions, where the EU has legislated for the world it wants — on deforestationcarbon and due diligence — and asked its partners to meet it there.  

That bargain is fraying. As the EU increasingly stakes its credibility on environmental standards — embedding them in trade deals and green partnerships — it is judged by whether it enforces them or allows them to weaken under pressure or once they reach implementation. With geopolitical rivalry intensifying and competition for partners fierce, the Union can no longer dismiss how its record is read. 

The EU must move from 'pledge diplomacy' — ambitions that outrun implementation, rules that bend under lobby pressure — to 'delivery-based multilateralism' – enforcing in full the commitments it has already made. 

Two fronts, two kinds of failure 

The following two cases illustrate the two ways the EU fails to deliver on the standards it sets. 

The EU-Mercosur Agreement is the starkest test of a failure of political will. Provisionally applied since 1 May 2026, the deal is the EU's largest ever: it scraps tariffs on 92% of Mercosur imports in exchange for access to South America’s markets and minerals. It grants Mercosur its largest-ever beef quota, the concession that drove five member states to vote against it. Beef is also one of the seven commodities the European Union Deforestation Regulation (EUDR) was built to govern, by requiring importers to prove their goods were not grown on cleared land.  

Deforestation is not the deal’s only environmental problem — the carbon footprint of beef is another — but the EUDR is what makes the Mercosur deal’s environment-related promises credible: without it, agricultural liberalisation is simply an invitation to deforest. Yet the EUDR has been delayed twice, and the Commission now proposes to strip cattle hides and leather from its scope before it applies in December 2026. In other words, the EU is opening its Single Market and weakening environmental safeguards for all sides at once. 

The Critical Raw Materials Act (CRMA), backed by Clean Trade and Investment Partnerships (CTIPs), presents a second case revealing the failure of institutional design. Critical raw materials — lithium, cobalt, copper and rare earths — are the physical basis of the energy transition: no batteries, no wind turbines, no grids without them. The EU imports almost all of them, and China refines most of the world's supply, making European CRM supply chains extremely vulnerable.  

The CRMA and CTIPs are the EU's answer: billed as a cleaner alternative to Chinese extraction, they promise secure supply through partnerships with resource-rich countries, held to European environmental and labour standards. The test it sets up is whether a cobalt mine in the DRC or a copper project in Kazakhstan must meet the environmental and labour standards the EU imposes on the same operations at home.  

As currently structured, it does not. For Strategic Projects abroad, those standards are not independently enforceable: the CRMA leans on host-country frameworks and referenced guidance — OECD due diligence, UN Guiding Principles — rather than a binding EU requirement. This gap is a direct consequence of the CTIPs governance deficit: with no direct EVP mandate over the CTIPs, and key commissioners — including the energy commissioner — excluded from their design, no actor in the Commission structure is mandated to require equivalent conditionality across internal and external projects. 

Both cases share a further weakness. The EU's green partnerships routinely stall between political signature and bankable delivery: fragmented de-risking instruments, no reliable project pipeline, and standards that arrive after the deal is struck rather than shaping it. 

What delivery would require 

The EU's 2021 Joint Communication on rules-based multilateralism called for consistency between internal and external actions. What is missing is not the aspiration but the delivery. Three actions would provide it, each addressing a distinct layer of the failure identified above. 

To fix the political will gap, the Council and Parliament should rule out a third postponement of the EUDR and reject the pending delegated act that would strip cattle hides and leather from its scope. Holding that line before the regulation applies in December 2026 is what keeps the deal's central environmental promise from becoming a dead letter the moment the deal takes effect. 

To fix the institutional design gap, the Commission President should revise the mandates of the coordinating Executive Vice-Presidents to give them direct oversight of the CTIPs, with cross-domain conditionality built into each partnership's design from the outset. Without that mandate revision, the governance deficit that produced the CRMA's conditionality gap persists. If properly governed, CTIPs could also set the template for how future trade agreements embed enforceable sustainability conditionality. 

To address the shared gap, the Commission should attach to each external partnership a pipeline of bankable projects from the outset. That pipeline should be co-financed through Global Gateway with the finance institutions that will carry the projects — member states' finance institutions, the European Investment Bank (EIB) and European Bank for Reconstruction and Development (EBRD) — brought in early enough that their safeguard standards shape the partnership's terms rather than arrive too late to bind them. Finance and standards would then form part of the partnership itself.  

Taken together, these three actions would close the delivery gap that threatens the bargain the EU's multilateral influence rests upon. The Union's word will travel no further than its willingness to enforce it.  

 

Michele Galli is Adviser on EU and Global Sustainable Development at the EPC and a Strategic Council member.  

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