In the European Green Deal presented at the end of 2019, the EU set the goal of achieving climate neutrality across the Union by 2050, as well as “economic growth decoupled from resource use”. Several key pieces of legislation have been adopted and now need to be effectively implemented. However, several major projects remain ongoing, whilst others have been scaled back, particularly in the areas of agriculture and biodiversity protection.

To achieve the objectives set out in the Green Deal, the EU has, during the 2019–2024 term, used trade policy as a tool and has begun to address the gap in production standards between European and imported products through the introduction of mirror measures. These measures, incorporated into European legislation, make access to the EU market conditional upon compliance with certain essential European standards relating to sustainability, the environment, health and animal welfare, in particular.

Whilst measures of this kind have existed for some time, mainly in the agricultural sector, they remained isolated. The Green Deal has ushered in a paradigm shift, as evidenced by the adoption of the Carbon Border Adjustment Mechanism, the regulation on imported deforestation and the regulation on neonicotinoid residues.

This report, an update of a paper published in September 2023, provides an overview of existing mirror measures implemented across various economic sectors within the context of the European Green Deal. It identifies other sectoral policies and legislations in which such measures could be adopted during the 2024–2029 European term to meet our international sustainability commitments and strengthen our strategic autonomy.

The current context, marked by numerous regulatory setbacks (the postponement of the entry into force of the regulation on imported deforestation; the first so-called ‘omnibus’ legislative proposal, notably concerning the due diligence directive), raises questions about the robustness of the environmental course set by the EU and, by extension, about the EU’s genuine willingness to implement mirror measures. The scaling back of ambition in this area during the preparation of the vision for agriculture, presented by Commissioner Hansen on 19 February 2025, is evidence of this ambivalence; as is the simultaneous presentation on 26 February of a Clean Industrial Deal and proposals to dismantle several key pieces of Green Deal legislation.

Recommendations

• Clarify that our decarbonisation and biodiversity protection targets also apply to products imported for our consumption and set a clear trajectory for reducing the EU’s carbon footprint and pesticide footprint. A carbon footprint target should be included in the legislative proposal to be presented in July 2025 by the Commission, including a 2040 target for the climate law.

• Undertake a systematic review of the relevance and usefulness of a section dedicated to the treatment of imported goods and services for each major European text (in impact studies, consultations and the drafting of legislative proposals).

• Clarification of responsibilities and creation of more robust means of monitoring compliance with environmental and health standards for imported products.

• Develop the customs nomenclature to show certain distinctions between products according to their production methods, for example organic farming products, recycled products, green steel or green steel products.

• Effectively implement the mirror measure on veterinary medicinal products in livestock farming and extend this rule to cover antibiotics considered as feed additives.

• Short-term reduction of maximum residue limits (MRLs) to the detection threshold for all hazardous pesticides banned in the EU and extension of MRL use to all agricultural production (including crops intended solely for animal feed, energy or ornamental use). In the medium term, adoption of a total import ban on products treated with pesticides banned in the EU.

• Ban the production in the EU for export of banned pesticides (and the substances that they are composed of) whose use is prohibited in the EU because of their danger to health or ecosystems.

• Adoption of ambitious new rules on sustainable food systems, animal welfare and eco-design of products, including mirror measures.