TRADE & ENVIRONMENT
Trade policies must anticipate and address environmental impact. In this context, TULIP focuses on how to design international legal frameworks that encourage sustainable trade while minimizing negative environmental externalities. Moreover, it is critical that green trade measures take into account development implications on trading partners. TULIP's work on the trade-environment-development nexus focuses on what actions countries can take to address possible negative implications of green and sustainable trade measures on developing countries. It further highlights pragmatic ways for producer countries in the Global South to leverage trade and trade policy, in order to achieve their own environmental, economic and industrial policy objectives.
Critical Raw Materials
The Circular Economy
Biodiversity Protection
Decarbonization
Sustainable Agriculture
PUBLICATIONS
In collaboration with Europe Jacques Delors
Clean Trade and Investment Partnerships: Unpacking the EU-South Africa CTIP​
Op-ed, April 2025
During the EU-South Africa summit in March 2025, the Commission launched negotiations with South Africa to develop a Clean Trade and Investment Partnership (CTIP). This would be the first CTIP the EU will negotiate. While many elements of these partnerships remain unclear – including their legal nature and governance structure – the announcement of the EU-South Africa CTIP provides initial insights into what we can expect from these novel partnership instruments. In the case of South Africa, a key interest for the EU seems to be accessing green hydrogen. This presents important export and employment opportunities for South Africa but should not come at the expense of sustainable development and the greening of domestic industries.
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Click here to access the opinion piece
In collaboration with Europe Jacques Delors
Policy brief, March 2025
Clean Trade and Investment Partnerships (CTIPs) are presented as a flexible tool for engaging with partners, helping the EU better navigate the current geopolitical context while accessing strategic markets, critical raw materials, and clean technology and energy. Drawing on best practices, this discussion paper offers policy options to consider as the Commission begins negotiating CTIPs, focusing on a strategic prioritisation; scope; legal nature; commitments; monitoring and enforcement, and governance.
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Click here to access to discussion paper
Commissioned by UNIDO
​The cost of sustainability regulations: Pathways for a fair distribution​
Policy brief, March 2025
Countries around the world are adopting sustainability-driven regulations, imposing mandatory requirements for more sustainable production and trade. Adapting to these new requirements comes at a cost, both for businesses and at the country level and there are increasing concerns, particularly in industrializing countries, about the burden that these costs may represent. This policy brief contextualizes current discussions, by distinguishing between different types of sustainability-driven supply chain regulations and associated costs of compliance.
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Click here to access the policy brief.
Commissioned by Transport and Environment
Technical Report, June 2024
This report examines energy and raw materials (ERM) and trade and sustainable development (TSD) chapters in ten EU FTAs to assess whether the EU’s approach balances securing access to raw materials (RMs) for the green transition with sustainability considerations relevant to mining, and green industrial policy objectives in the resource-rich countries.
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Click here to download the report.
This report was cited in Alan Beattie's Trade Secret Column in the Financial Times.
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In collaboration with Europe Jacques Delors ​
Turning the EU's CBAM Mechanism into a Green Development Tool
Policy Brief, April 2024
The CBAM has provoked considerable debate worldwide and strong reactions by EU trading partners. This policy brief calls for a shift away from these seemingly irreconcilable positions, towards a more constructive approach from both the EU and its trading partners. The authors suggest carrying out impact assessments that could serve as a basis for the EU to fine-tune and step up support efforts. This brief thereby presents a pathway to using CBAM as a tool for green development.
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​Click here to access the policy brief
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Journal of International Economic Law - Special feature: Remaking the Trading System
Academic article, March 2025
​​Trade is critical to unlocking the global circular transition. However, low- and middle-income countries (LMICs) often struggle to reap these benefits. With a focus on Africa’s textile and apparel sector, this article explores how LMICs can leverage trade and trade agreements to accelerate a circular transition domestically. It identifies circular economy opportunities in the textile and apparel sector in Africa, and includes an analysis of how African countries can leverage relevant agreements of the World Trade Organization (WTO) and the African Continental Free Trade Area (AfCFTA) to unlock these opportunities. In doing so, this article highlights the need for LMICs to adopt a proactive approach to fully utilize the opportunities presented by the circular transition.
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This article is protected by a paywall.
Commissioned by Fern
​WTO Implications of the proposed "no risk" amendment to the Deforestation-free Products Regulation
Legal Analysis, December 2024
This legal analysis undertakes a preliminary assessment of the “no risk” amendment, proposed to the EUDR in December 2024 . The analysis finds that, should the “no risk” amendment be adopted, it would likely render the EUDR inconsistent with various provisions of the WTO covered agreements. In particular, a Regulation with a “no risk” exemption would amount to impermissible discrimination in violation of GATT Articles I and III. Moreover, such WTO inconsistencies would not be justifiable under the general exceptions clause of GATT Article XX as the “no risk” exemption would likely constitute arbitrary of unjustifiable discrimination under the chapeau of that provision. Should a panel find the EUDR to be a technical regulation, it would likely also violate Article 2.1 of the TBT Agreement.
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You can access the analysis here.
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Commissioned by the World Trade Organization
​Emerging Trade Opportunities for LDCs from the Green Transition
Policy Brief, June 2024
As the effects of climate change become increasingly palpable, policy makers around the world face the unprecedented challenge of transitioning towards a net-zero world. Yet this is not their only challenge. Policy makers must also ensure that net-zero transition does not create a “green divide” – between countries that have the necessary resources to invest in and develop green value chains and products, and countries which are at risk of being excluded from the green transition due to lack of resources. This article identifies various ways in which such green divide can be overcome.
You can read the article here. ​ ​​
Commissioned by Public Waste Agency of Flanders (OVAM)
The Missing Piece of the EU Green Deal - The Case for an EU Resources Law
Technical Report, January 2024
This report, drafted for OVAM by TULIP Consulting and IEEP, suggests that the EU’s excessive extraction, production, manufacturing and consumption of material resources needs to be explicitly addressed. EU consumption is currently around double the estimated sustainable level, and tackling this is necessary to support successful implementation of the EU’s Green Deal, climate change targets and circular economy goals.
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Click here to download the study.
Colette van der Ven presented the study's key findings during the World Circular Economy Forum in 2024, which can be watched here. ​​
In collaboration with Europe Jacques Delors
A pro-development green trade agenda for COP28
Policy Brief, November 2023
​​The UN Climate Conference (COP28) is remarkable for several reasons, one of them being the debut of trade in the Official COP Programme, recognizing trade’s pivotal role in climate solutions. This policy brief aims to explore development-friendly approaches to two climate mitigation policies: carbon pricing and border carbon schemes, and trade in transition minerals which are critical to achieving our common mitigation goals.
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Click here to access the policy brief
Global Trade and Customs Journal
Responding to the EU Green Deal: A proactive approach to trade and green industrial policy in Africa
Academic article, 2024
​​The EU Green Deal and its host of accompanying trade measures have put its trading partners on the defense, scrambling to find the right policy response. The approach adopted by many developing countries and Least-Developed Countries (LDCs) is mostly reactive. This article argues that for the EU Green Deal to be used as a development tool, EU trading partners must go beyond reacting to EU green trade measures, and instead adopt a proactive approach. This article illustrates what a proactive approach to the EU Green Deal could look like for African countries, with a focus on the EU Ecodesign for Sustainable Products Regulation (ESPR) and the Critical Raw Materials Act (CRMA).
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This piece is protected by a paywall
In collaboration with Europe Jacques Delors
EU Trade and Environment: Development as the Missing Side of the Triangle
Policy Brief, June 2023
The authors of this publication believe that the EU should acknowledge that greening its trade is affecting, and will disproportionately affect, some of its most vulnerable trading partners and re-integrate more of the development dimension in the conduct of its green trade policy. Designing the contours of this reaction is the purpose of this policy brief.
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Click here to access the policy brief.
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Commissioned by GIZ
Making trade work for an inclusive circular transition
Technical Report, September 2023
The role of trade law and policy in the circular economy transition is receiving increased attention. Most trade-related initiatives and studies focus predominantly on advancing the circular economy transition from the vantage point of developed countries, reflecting the fact that developed countries tend to be better positioned to reap the benefits associated with a circular transition compared to developing and least developed countries (LDCs). To avoid creating a 'circular divide', it is imperative to ensure that the global circular economy transition not only reduces material resource consumption and production, but also reduces inequalities between developed countries and developing countries/LDCs. This report provides an in-depth analysis of how the World Trade Organization and Regional Trade Agreements can be leveraged to advance an inclusive circular transition.
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The study can be downloaded here.
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Commissioned by the Finnish Innovation Fund SITRA
Circular innovation and ecodesign in the textiles sector
Technical Report, September 2022
In March 2022, the European Commission submitted a proposal for a regulation for Eco-Design for Sustainable Products (ESPR). The proposal establishes a framework for ecodesign requirements that can be applied to specific product groups to enhance their durability and sustainability. To better understand the implications of the ESPR on developing countries, this paper zooms in on how the ESPR will impact the garment industry in Bangladesh, Sri Lanka, and Vietnam.
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Click here to download the study.
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This study was launched at the WTO Public Forum 2022, and main take-aways from the session can be viewed here.
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Commissioned by World Wildlife Fund (WWF) UK
Exploring implications of core environmental standards for the UK
​Technical Report, December 2022
While UK farmers are required to comply with stringent environmental requirements, these requirements are not imposed on imposed on imported products. This report has developed a methodology on the basis of which imposing similar standards on imported products could be developed, taking into account the WTO rules, as well as developing country considerations. It includes two case studies, one focused on the pesticides known as neonicitinoids, and one focused on nitrogen use. ​
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Click here to access the full technical report; and here to download the think piece.
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Commissioned by The Public Waste Agency of Flanders (OVAM)
International Agreement on Natural Resource Management
Technical Report, February 2022
This report seeks to contribute to exploratory conversations on developing an international agreement on natural resource management. It finds that developing an international agreement on natural resource management would fill an important gap in existing trade and environment treaties and initiatives and could be critical in reducing overexploitation of resources in the decades to come. It could galvanize coordinated action at a global scale, which would be important to avoid-free riding and to ensure global levels of material consumption remain within planetary boundaries. This report further finds that adopting a gradual approach to an international agreement on resource management would be the preferred course of action..
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Click here to download the study.
Commissioned by the World Economic Forum
Trade and the Circular Economy: A Deep Dive into Plastics Action in Ghana
Policy brief, October 2022
This report sets out ways in which Ghana can leverage trade policy frameworks, including the African Continental Free Trade Area, to address plastic pollution and achieve a circular plastics economy. The research and recommendations form a preliminary assessment and complement the Roadmap for Radical Reduction of Plastic Pollution in Ghana.
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Click here to download the paper
Click here to download a summary blog post
Consultant to United Nations Environment Progamme (UNEP)
Sustainable Trade in Resources: Global Material Flows, Circularity, and Trade
Technical Report, 2022
The purpose of this discussion paper is to enhance understanding among trade and environment
policymakers regarding trade flows of material resources – including their environmental impacts – and
regarding trade’s potential to contribute to the transition to a greener, more circular economy. The paper summarises the Internatioanl Resource Panel’s analysis on so-called upstream requirements of trade flows, drawing on previous reports.
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Click here to access the report.
Commissioned by the Organization of Economic Cooperation and Development (OECD)
Technical Report, December 2020
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Click here to download the paper.
In collaboration with Europe Jacques Delors
Policy Brief, December 2022
This policy brief explores the origin of essential element clauses and the rationale of applying them to MEAs. It develops parameters to assess what other MEAs could appropriately be considered essential elements of future EU FTAs. Finally, it explores, with an emphasis on the Paris Agreement, how to operationalize essential provisions in MEAs by distilling provisions that set out the “essence” of the MEA.
Click here to access the policy brief.
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Commissioned by the Permanent mission of the Netherlands to the WTO
The Circular Economy, Trade and Development: Addressing Spillovers and Leveraging Opportunities
Technical Report, 2020
This paper aims to obtain a clearer understanding of the linkages between the circular economy, trade, and development, and the various tools available to developing economies to leverage opportunities and mitigate any negative spillovers. It is organized in two sections: the first section maps out different ways in which advanced countries’ circular economy roadmaps might impact trade flows with developing economies. The second part focuses on how the effective use of trade policy can contribute to rendering the transition towards a circular economy more inclusive. It does so by looking at the role of domestic governments, RTAs, and the WTO in helping developing economies capitalize on advanced economies’ transitions to a circular economy.
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Click here to download the paper
Commissioned by the Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ)
Technical Report, 2020
​In the context of the upcoming expiration of the EU GSP, this study recommends concrete ways to improve the GSP scheme's functioning. For each GSP regime – Standard GSP, GSP+, and EBA – this study has provided a number of reform options, taking into account the anticipated benefits of the reform and the proposals' technical, legal and political feasibility. It focuses on rules of origin, product coverage, cumulation, transitional phases, and GSP+ requirements.
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Click here to access the study.
In collaboration with Europe Jacques Delors
Exploring the interface between unilateral and bilateral approaches to greening trade
Policy Brief, March 2023
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Click here to access the policy brief.
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In collaboration with the London School of Economics and the African Climate Foundation
Implications for African countries of a Carbon Border Adjustment Mechanism in the EU
Technical Report, May 2023
This report sets out the implications of the CBAM for Africa regarding relevant obligations under international legal frameworks as well as strategic considerations for African countries, ensuring the CBAM is designed and implemented in such a way that is neither more trade restrictive than necessary nor discriminatory. The CBAM will be introduced on 1 October 2023, with a three-year transition period during which only emissions reporting obligations will apply, without any financial payments or adjustments. After the transition period, the CBAM will be gradually phased in from 2026 to 2034. It will initially cover imports of iron and steel, cement, aluminium, fertiliser, hydrogen, and electricity.
Click here to access the report.
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