Assessing the 'sustainable' impact of EU trade deals

This is the T&E’s response to the European Commission’s public consultation on the handbook on Sustainability Impact Assessment (SIA). 

Amongst the key elements of our review of the SIA, we highlight the following - for the full response click on the link at the bottom of this page:

We maintain that integrated impact assessments are essential in order to properly examine the economic, social, human rights and environmental effects that trade agreements have.

The precautionary principle is surprisingly not mentioned in SIA handbook. What might be deemed to be the most trade cost-effective might be in contradiction to the precautionary principle.

T&E believes that the SIA handbook lacks clear and detailed guidelines as to how categories will be addressed. For instance, on the assessment of transport, all SIAs must examine the effects of trade on transport (aviation, maritime, road and rail). In particular, establishing existing transport links between the EU and the proposed trading partner, mapping the status quo by: freight weight; greenhouse gas emissions (GHG); air quality (sulphur, nitrogen oxides and particulate matters); noise (dense urban areas, motorways and airports). 

One major criticism of the current EU SIA process has been that the studies have come too late to have a real influence, or that the negotiation timetable was too tight to leave a chance for carrying out a corresponding in-depth analysis of impacts, other than the purely cost-effectiveness one. SIAs should not only inform the negotiation process, but should begin before negotiation positions are even formulated, as otherwise important decisions will already have been taken.

The Commission should also be held accountable for ensuring that the SIA recommendations and outcomes are upheld – even if the final conclusion is to stop negotiations.

The SIAs should be updated and account for changes to assumptions initially held at the start the process. These pre- and post-negotiation conclusions should become part of the debate as agreements are discussed in the Council, the European and National Parliaments. Without this pre- and post-assessment update, it is impossible to anticipate the full impact of any agreement and thus make truly informed political decisions that impact the lives of 500 million Europeans.