AUTHORS: Pierre Leturcq, Nora Hiller, Eline Blot, Irene Chiocchetti, and Antoine Oger

This report aims to foster a European-level reflection on the coherence between the European Union’s internal and external policies, with a particular focus on the spillover effects of EU trade-related sustainability policies.

Since 2019, under the framework of the European Green Deal, the European Union has introduced a series of environmental measures with significant implications for global value chains (GVCs). These include, among others, the Carbon Border Adjustment Mechanism (CBAM), the Regulation on deforestation-free products (EUDR), the Corporate Sustainability Due Diligence Directive (CSDDD), and the Ecodesign for Sustainable Products Regulation (ESPR). These measures, which carry extraterritorial dimensions, have triggered concern among stakeholders in various regions—from the BRICS countries (Brazil, Russia, India, China, South Africa, UAE) to actors in low- and middle-income countries (LMICs)—who fear unfair and asymmetric access to the EU market.

A recurring criticism of the European Green Deal agenda concerns the lack of prior consultation in the policymaking process and the insufficient inclusion of economic actors from the most vulnerable economies (those heavily dependent on access to the European market), and a fragmented external outreach from the European Commission, with different Directorate-Generals of the European Commission managing international dialogues in an uncoordinated manner. The diversity of methods employed in this project is primarily aimed at fostering inclusion, beginning with feedback from international partners, with particular attention given to the African continent. The insights gathered through the Barometer and structured interviews enabled a strategic prioritisation of the policies to be addressed.

To explore the geopolitical dimensions of these developments and understand how they are perceived outside the EU, this report draws on extensive qualitative research involving stakeholders in LMICs, with a specific focus on Africa. The research was conducted through two main formats:

• A large-scale expert survey, the fifth edition of the European Green Deal Barometer, which gathered insights from both European and non-European experts to categorise attitudes toward the Green Deal (see Section 1).
• A series of structured interviews with African experts, providing deeper insight into regional challenges, expectations, and engagement strategies (see Section 2). This edition of the Green Deal Barometer has been adapted into a platform for structured engagement with non-European experts, particularly on the African continent.

Rather than focusing primarily on the economic or social tensions that may result from EU environmental regulations, this report highlights the potential for constructive engagement and international cooperation. It recognises the complexity of the issues at stake, particularly for LMIC stakeholders navigating the evolving EU regulatory landscape.

The report is organised into three parts:

• Section 1 presents the findings of the Green Deal Barometer survey, mapping international perceptions of EU Green Deal policies.
• Section 2 summarises the outcomes of structured interviews with African experts, identifying key themes and concerns.
• Section 3 compiles three policy papers that analyse in depth the three most frequently mentioned regulatory measures—CBAM, EUDR, and ESPR.

These papers, published between March and June 2025, were further informed by expert discussions held during a roundtable in Warsaw on 28 March 2025, hosted under the Polish Presidency of the Council of the EU. The project concludes by examining the role of foreign policy instruments and trade partnerships as platforms for cooperation that could help ease tensions arising from the implementation of these regulatory tools.

Together, these three sections aim to provide an initial yet comprehensive basis for policy dialogue on how the EU’s sustainability agenda can align more effectively with the realities and priorities of its global partners.