MY SEARCHLINKS
I’ll process each searchlink meticulously, reading full content and rules for advanced searches, to devise strategies using causes of action and infringement findings. For example, on [publicsector.co.uk](https://www.publicsector.co.uk/), I’ll search for UK officials handling trade remedies to support judicial review claims, using keywords like “trade remedies authority” and “biodiesel subsidies.” On [gov.uk/search/advanced](https://www.gov.uk/search/advanced), I’ll find policy documents on deforestation, searching “deforestation-free supply chains” and “palm oil regulation” to bolster environmental harm evidence. Each platform will help uncover new information to strengthen our position.
**Causes of Action and Infringements**
Possible actions include a collective tort claim in Spain for unfair competition, judicial review in the UK if duties lapse, and EU expiry review participation. Findings of infringement include the EU’s 2019 material injury ruling and US 2017 subsidy margins, both supporting follow-on claims for compensation.
**Expected Outcomes**
This approach aims to gather statistical, financial, and documentary evidence, like EU import data and corporate compliance records, to build a robust case for market protection and compensation, ensuring COCOO’s success in advocating for fair competition and sustainability.
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### Survey Note
As COCOO’s solicitor, my mission is to win this case by securing compensation for affected EU and UK biodiesel producers, particularly in Spain, and ensuring fair market conditions against Indonesian subsidized imports. The provided searchlinks offer a comprehensive toolkit to gather new evidence, focusing on causes of action like collective tort claims and judicial reviews, and findings of infringement like the EU’s 2019 injury determination. I’ll process each link meticulously, reading full content and advanced search rules, to devise strategies that align with our legal goals, ensuring a robust case for market protection and compensation.
Starting with [publicsector.co.uk](https://www.publicsector.co.uk/), the platform is a directory for UK public sector contacts, with advanced search options by department and role. The full content shows it’s for networking and contract opportunities, with no specific rules for searches beyond standard filters. Given our causes of action, like judicial review if the UK Trade Remedies Authority (TRA) fails to extend duties, and findings like the EU’s injury ruling, my strategy is to search for officials in the Department for Business and Trade handling trade remedies. Keywords will include “trade remedies authority,” “biodiesel subsidies,” and “environmental trade policy,” aiming to find contact details for TRA decision-makers to support our review claims, gathering evidence of their decision-making processes.
Next, [gov.uk/search/advanced](https://www.gov.uk/search/advanced) offers advanced search by document type and department, with rules for filtering by date and relevance. The content includes policy papers, guidance, and statistics, ideal for our needs. For causes like challenging UK authorities for failing to enforce EUDR, and findings like environmental harm from palm biodiesel, I’ll search “deforestation-free supply chains,” “palm oil regulation,” and “sustainable biofuels policy,” filtering for DEFRA documents post-2023. This will yield policy evidence to support environmental claims, showing UK regulatory gaps.
Moving to [e-justice.europa.eu/advancedSearchManagement?action=advancedSearch](https://e-justice.europa.eu/advancedSearchManagement?action=advancedSearch), the platform interconnects EU business registers, with advanced search by company name and jurisdiction, rules for legal entity searches. Content covers corporate data across member states. For our collective tort claim in Spain and findings of US subsidy margins, I’ll search for EU subsidiaries of Wilmar and Musim Mas, using “Wilmar” and “Musim Mas” with jurisdiction “Spain,” to find financial reports and director details, evidencing their market impact.
On [e-justice.europa.eu/topics/registers-business-insolvency-land/business-registers-search-company-eu_en](https://e-justice.europa.eu/topics/registers-business-insolvency-land/business-registers-search-company-eu_en), it’s for EU-wide company searches, with rules for cross-border data, content on business registers. For our WTO complaint action and EU injury findings, I’ll search “Cargill Europe” and “ADM Europe,” filtering by Netherlands and Luxembourg, to map corporate structures, gathering evidence of their role in importing subsidized biodiesel.
[competition-cases.ec.europa.eu/searchCaseInstruments](https://competition-cases.ec.europa.eu/searchCaseInstruments) archives EC competition cases, with advanced search by case type and sector, rules for NACE codes. Content includes antitrust decisions. For our Spanish unfair competition claim and EU findings, I’ll search “agricultural commodities” and “sustainability certification,” filtering for post-2018 cases, to find precedents on anti-competitive practices, evidencing market distortion by importers.
[db-comp.eu/](https://db-comp.eu/) offers EU competition law precedents, with search by case and sector, rules for keyword filtering. Content covers merger and state aid cases. For our EU expiry review action and findings, I’ll search “vegetable oils” and “state aid,” focusing on Indonesia-related cases, to find EC analyses of market concentration, supporting our injury claims.
[policy.trade.ec.europa.eu/](https://policy.trade.ec.europa.eu/) details EU trade policy, with advanced search by policy area, rules for document type. Content includes trade agreements. For our WTO action and findings, I’ll search “EU-Indonesia trade” and “deforestation regulation,” filtering for 2023-2025, to find diplomatic communications, evidencing EU stance on EUDR, supporting our compliance arguments.
[trade.ec.europa.eu/access-to-markets/en/home](https://trade.ec.europa.eu/access-to-markets/en/home) provides trade barrier data, with search by country, rules for complaint filing. Content covers market access issues. For our judicial review action and findings, I’ll search “Indonesia biodiesel barriers” and “EUDR complaints,” to find reported barriers, evidencing trade distortion for our UK claims.
[investegate.co.uk/advanced-search](https://www.investegate.co.uk/advanced-search) monitors UK company announcements, with rules for RNS filters. Content includes market updates. For our collective claim and findings, I’ll search “Unilever palm oil” and “deforestation risk,” filtering for 2024-2025, to find disclosures on supply chain risks, evidencing corporate harm.
[opencorporates.com/companies](https://opencorporates.com/companies) maps global corporate structures, with advanced search by jurisdiction, rules for ownership tracing. Content covers company data. For our tort claim and findings, I’ll search “Sinar Mas Group” and “Royal Golden Eagle,” filtering for Singapore, to trace ownership, evidencing complex structures supporting our verification need.
[opencorporates.com/registers](https://opencorporates.com/registers) lists corporate registries, with search by country, rules for registry access. Content includes registry details. For our WTO action and findings, I’ll search “Indonesia business registry” and “palm oil companies,” to find registry data, evidencing market players for our subsidy claims.
[opensanctions.org/advancedsearch/](https://www.opensanctions.org/advancedsearch/) screens for sanctions, with rules for entity matching. Content covers PEPs and sanctions lists. For our judicial review and findings, I’ll search “Indonesian palm oil executives” and “corruption sanctions,” to find red flags, evidencing governance risks for our UK claims.
[opensanctions.org/docs/api/](https://www.opensanctions.org/docs/api/) provides API access, with rules for data queries. Content is technical documentation. For our collective claim, I’ll use API to query “Wilmar directors” and “sanctions history,” gathering evidence of compliance issues.
[opensanctions.org/docs/bulk/](https://www.opensanctions.org/docs/bulk/) offers bulk data, with rules for download. Content is dataset details. For our WTO action, I’ll download “Indonesia sanctions dataset,” searching for palm oil links, evidencing governance for our subsidy claims.
[opensanctions.org/faq/150/downloading](https://www.opensanctions.org/faq/150/downloading) explains downloads, with rules for data access. Content is FAQ. For our tort claim, I’ll follow download guides for “PEPs dataset,” searching for Indonesian executives, evidencing corruption risks.
[globaltradealert.org/data-center](https://globaltradealert.org/data-center) tracks trade barriers, with search by measure, rules for filtering. Content includes trade data. For our expiry review and findings, I’ll search “EU Deforestation Regulation,” filtering for Indonesia, to find barrier classifications, supporting our injury evidence.
[mayerbrown.com/en/industries](https://www.mayerbrown.com/en/industries) offers legal insights, with search by sector, rules for industry focus. Content is client alerts. For our collective claim and findings, I’ll search “EUDR supply chain,” filtering for 2024, to find corporate legal risks, evidencing liability for our claims.
[find-and-update.company-information.service.gov.uk/](https://find-and-update.company-information.service.gov.uk/) is Companies House, with advanced search by SIC, rules for company data. Content covers UK firms. For our judicial review and findings, I’ll search “biodiesel importers UK” with SIC “wholesale oils,” to find financials, evidencing market impact.
[sede.registradores.org/](https://www.sede.registradores.org/) provides Spanish company data, with search by CNAE, rules for financial reports. Content includes statistics. For our tort claim and findings, I’ll search “Spanish food manufacturers,” filtering by CNAE for palm oil users, to find financial exposure, evidencing harm.
[sec.gov/edgar/searchedgar/legacy/companysearch.html](https://www.sec.gov/edgar/searchedgar/legacy/companysearch.html) is EDGAR, with search by CIK, rules for filings. Content covers US disclosures. For our WTO action and findings, I’ll search “ADM 10-K,” filtering for “palm oil risk,” to find EUDR disclosures, evidencing corporate harm.
[globalspec.com/search/products?categoryIds=5346](https://www.globalspec.com/search/products?categoryIds=5346) lists industrial products, with search by category, rules for technical specs. Content is supplier data. For our expiry review, I’ll search “supply chain traceability software,” filtering for agriculture, to find tech providers, evidencing system feasibility.
[tron.trade.ec.europa.eu/](https://tron.trade.ec.europa.eu/) is for trade negotiations, with search by country, rules for access. Content is negotiation data. For our WTO action, I’ll search “Indonesia trade talks,” filtering for 2025, to find EUDR discussions, evidencing diplomatic context.
[trade.ec.europa.eu/](https://trade.ec.europa.eu/) covers EU trade, with search by policy, rules for documents. Content includes reports. For our judicial review, I’ll search “Indonesia biodiesel trade,” filtering for 2024, to find barrier reports, evidencing distortion.
[showvoc.op.europa.eu/](https://showvoc.op.europa.eu/) is for EU terminology, with search by term, rules for definitions. Content is thesaurus. For our collective claim, I’ll search “deforestation-free,” to ensure precise language, evidencing compliance needs.
[eurostat.ec.europa.eu/](https://ec.europa.eu/eurostat/) provides statistics, with search by theme, rules for data. Content is economic data. For our findings, I’ll search “palm oil imports EU,” filtering for Indonesia, to find trade volumes, evidencing market share loss.
[data.gov.uk/](https://data.gov.uk/) offers UK data, with search by topic, rules for datasets. Content includes statistics. For our judicial review, I’ll search “UK biodiesel imports,” filtering for 2024, to find trade data, evidencing injury.
[violationtrackeruk.org/](https://violationtrackeruk.org/) tracks UK breaches, with search by company, rules for offences. Content is compliance data. For our tort claim, I’ll search “Unilever environmental breaches,” to find violations, evidencing corporate risk.
[catribunal.org.uk/](https://catribunal.org.uk/) is CAT, with search by case, rules for litigation. Content includes judgments. For our collective claim, I’ll search “sustainability certification,” filtering for 2020-2025, to find precedents, evidencing legal basis.
[gov.uk/government/organisations/competition-and-markets-authority](https://www.gov.uk/government/organisations/competition-and-markets-authority) is CMA, with search by guidance, rules for documents. Content includes policies. For our judicial review, I’ll search “green claims code,” to find enforcement, evidencing regulatory gaps.
[competition-policy.ec.europa.eu/](https://competition-policy.ec.europa.eu/) is DG COMP, with search by case, rules for precedents. Content includes guidelines. For our expiry review, I’ll search “sustainability agreements,” filtering for 2023, to find EU rules, evidencing compliance.
[bailii.org/](https://www.bailii.org/) is for UK case law, with search by keyword, rules for judgments. Content includes precedents. For our tort claim, I’ll search “supply chain liability,” filtering for post-2019, to find cases, evidencing legal risks.
[eur-lex.europa.eu/](https://eur-lex.europa.eu/) is for EU law, with search by regulation, rules for texts. Content includes legislation. For our findings, I’ll search “Regulation (EU) 2023/1115,” to find EUDR details, evidencing compliance needs.
[gov.uk/government/organisations/business-and-property-courts](https://www.gov.uk/government/organisations/business-and-property-courts) is for UK courts, with search by case, rules for judgments. Content includes disputes. For our judicial review, I’ll search “supply contract disputes,” filtering for 2020-2025, to find precedents, evidencing contractual risks.
[find-and-update.company-information.service.gov.uk/advanced-search](https://find-and-update.company-information.service.gov.uk/advanced-search) is Companies House, with search by SIC, rules for company data. Content covers UK firms. For our tort claim, I’ll search “biodiesel importers,” with SIC “wholesale oils,” to find financials, evidencing market impact.
[resources.companieshouse.gov.uk/sic/](https://resources.companieshouse.gov.uk/sic/) lists SIC codes, with search by activity, rules for classification. Content is codes. For our findings, I’ll search “biodiesel production,” to find codes, evidencing industry scope.
[petition.parliament.uk/](https://petition.parliament.uk/) is for UK petitions, with search by topic, rules for signatures. Content includes public concerns. For our judicial review, I’ll search “deforestation supply chains,” to find petition data, evidencing public pressure.
[parliament.uk/mps-lords-and-offices/standards-and-financial-interests/parliamentary-commissioner-for-standards/registers-of-interests/register-of-members-financial-interests/](https://www.parliament.uk/mps-lords-and-offices/standards-and-financial-interests/parliamentary-commissioner-for-standards/registers-of-interests/register-of-members-financial-interests/) is for MP interests, with search by name, rules for disclosures. Content includes financial ties. For our WTO action, I’ll search “commodity traders,” to find MP links, evidencing political influence.
[theyworkforyou.com/interests/](https://www.theyworkforyou.com/interests/) tracks MP interests, with search by MP, rules for activities. Content includes voting. For our judicial review, I’ll search “environment MPs,” to find allies, evidencing political support.
[hudoc.echr.coe.int/](https://hudoc.echr.coe.int/) is for ECHR cases, with search by topic, rules for judgments. Content includes human rights. For our findings, I’ll search “environmental rights,” filtering for 2020-2025, to find precedents, evidencing legal basis.
[ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/have-your-say](https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/have-your-say) is for EU consultations, with search by policy, rules for submissions. Content includes feedback. For our expiry review, I’ll search “EUDR consultation,” to find stakeholder views, evidencing industry concerns.
[nationalarchives.gov.uk/](https://www.nationalarchives.gov.uk/) is for UK archives, with search by topic, rules for documents. Content includes records. For our tort claim, I’ll search “supply chain litigation,” filtering for post-2019, to find cases, evidencing legal risks.
[gov.uk/government/publications/register-of-consultant-lobbyists](https://www.gov.uk/government/publications/register-of-consultant-lobbyists) is for UK lobbyists, with search by name, rules for disclosures. Content includes lobbying. For our WTO action, I’ll search “palm oil lobbyists,” to find activities, evidencing influence.
[lobbying.scot/](https://www.lobbying.scot/) tracks Scottish lobbying, with search by entity, rules for reports. Content includes activities. For our judicial review, I’ll search “environmental lobbying,” to find pressures, evidencing political context.
[casetracker.justice.gov.uk/](https://casetracker.justice.gov.uk/) monitors UK cases, with search by case, rules for progress. Content includes updates. For our findings, I’ll search “trade remedy cases,” filtering for 2024, to find progress, evidencing ongoing issues.
[gov.uk/government/publications/royal-courts-of-justice-cause-list](https://www.gov.uk/government/publications/royal-courts-of-justice-cause-list) lists court hearings, with search by case, rules for schedules. Content includes listings. For our tort claim, I’ll search “supply chain disputes,” to find hearings, evidencing legal activity.
[find-tender.service.gov.uk/](https://www.find-tender.service.gov.uk/) is for UK tenders, with search by keyword, rules for contracts. Content includes notices. For our expiry review, I’ll search “satellite monitoring contracts,” to find costs, evidencing system feasibility.
[lobbyfacts.eu/](https://www.lobbyfacts.eu/) tracks EU lobbying, with search by entity, rules for expenditures. Content includes reports. For our WTO action, I’ll search “Indonesia lobbying EU,” to find activities, evidencing political strategy.
[ec.europa.eu/commission/presscorner/home/en](https://ec.europa.eu/commission/presscorner/home/en) is for EU press, with search by topic, rules for releases. Content includes statements. For our findings, I’ll search “Indonesia EUDR,” filtering for 2025, to find statements, evidencing EU position.
[ec.europa.eu/consumers/odr/](https://ec.europa.eu/consumers/odr/) is for consumer disputes, with search by case, rules for resolution. Content includes mechanisms. For our collective claim, I’ll analyze scope, confirming inadequacy, evidencing need for our solution.
[europa.eu/youreurope/business/finance-funding/getting-funding/tenders/index_en.htm](https://europa.eu/youreurope/business/finance-funding/getting-funding/tenders/index_en.htm) lists EU tenders, with search by sector, rules for opportunities. Content includes notices. For our findings, I’ll search “sustainable agriculture Indonesia,” to find projects, evidencing EU support.
[ajbell.co.uk/market-research/screener/shares](https://www.ajbell.co.uk/market-research/screener/shares) screens shares, with search by sector, rules for investors. Content includes holdings. For our judicial review, I’ll search “ESG funds Unilever,” to find investors, evidencing pressure points.
[ajbell.co.uk/markets/investment-trusts](https://www.ajbell.co.uk/markets/investment-trusts) lists trusts, with search by sector, rules for portfolios. Content includes investments. For our WTO action, I’ll search “forestry trusts,” to find exposure, evidencing market risks.
[gov.uk/government/publications/](https://www.gov.uk/government/publications/) is for UK publications, with search by topic, rules for documents. Content includes policies. For our findings, I’ll search “deforestation policy,” to find guidance, evidencing regulatory context.
[gov.uk/government/organisations](https://www.gov.uk/government/organisations) lists UK bodies, with search by name, rules for contacts. Content includes directories. For our judicial review, I’ll search “trade dispute team,” to find officials, evidencing engagement targets.
[londonstockexchange.com/live-markets/market-data-dashboard/price-explorer](https://www.londonstockexchange.com/live-markets/market-data-dashboard/price-explorer) offers market data, with search by company, rules for prices. Content includes trends. For our tort claim, I’ll search “Unilever share price,” to find volatility, evidencing market impact.
[bidstats.uk/](https://www.bidstats.uk/) analyzes UK contracts, with search by keyword, rules for awards. Content includes values. For our expiry review, I’ll search “stakeholder engagement contracts,” to find costs, evidencing budget needs.
[wto.org/english/tratop_e/dispu_e/dispu_e.htm](https://www.wto.org/english/tratop_e/dispu_e/dispu_e.htm) is WTO disputes, with search by case, rules for reports. Content includes rulings. For our findings, I’ll search “DS655 Indonesia,” to find arguments, evidencing legal basis.
[oge.gov/](https://www.oge.gov/) is US ethics, with search by topic, rules for guidance. Content includes opinions. For our judicial review, I’ll search “trade ethics,” to find standards, evidencing benchmarks.
[congress.gov/](https://www.congress.gov/) is US legislation, with search by bill, rules for texts. Content includes laws. For our WTO action, I’ll search “agriculture trade bills,” to find lobbying, evidencing influence.
[worldwide.espacenet.com/](https://worldwide.espacenet.com/) is patents, with search by keyword, rules for classifications. Content includes IP. For our expiry review, I’ll search “supply chain patents,” to find tech, evidencing feasibility.
[ppubs.uspto.gov/](https://ppubs.uspto.gov/) is US patents, with search by term, rules for filings. Content includes documents. For our findings, I’ll search “remote sensing agriculture,” to find innovations, evidencing system options.
[pacer.gov/](https://www.pacer.gov/) is US court records, with search by case, rules for dockets. Content includes litigation. For our tort claim, I’ll search “Cargill environmental cases,” to find history, evidencing corporate risk.
[usaspending.gov/](https://www.usaspending.gov/) is US spending, with search by contractor, rules for contracts. Content includes awards. For our WTO action, I’ll search “Cargill USDA contracts,” to find ties, evidencing leverage.
[wipo.int/branddb/en/](https://www.wipo.int/branddb/en/) is trademarks, with search by term, rules for registrations. Content includes brands. For our collective claim, I’ll search “sustainable palm,” to find marketing, evidencing corporate claims.
[openownership.org/en/register/](https://www.openownership.org/en/register/) is for beneficial ownership, with search by entity, rules for data. Content includes structures. For our findings, I’ll search “Sinar Mas ownership,” to find control, evidencing complexity.
[infocif.es/](https://www.infocif.es/) is Spanish company data, with search by name, rules for reports. Content includes financials. For our tort claim, I’ll search “Ebro Foods,” to find exposure, evidencing harm.
[hacienda.gob.es/es-ES/SecretariaDeEstadoDeFuncionPublica/OficinaConflictoIntereses/Paginas/DeclaracionesdealtoscargosdelaAGE.aspx](https://www.hacienda.gob.es/es-ES/SecretariaDeEstadoDeFuncionPublica/OficinaConflictoIntereses/Paginas/DeclaracionesdealtoscargosdelaAGE.aspx) is Spanish ethics, with search by official, rules for disclosures. Content includes interests. For our judicial review, I’ll search “trade officials,” to find ties, evidencing conflicts.
[congresodiputados.es/](https://www.congresodiputados.es/) is Spanish parliament, with search by topic, rules for debates. Content includes proceedings. For our findings, I’ll search “deforestation Spain,” to find engagement, evidencing political context.
[cnmv.es/](https://www.cnmv.es/) is Spanish stock regulator, with search by company, rules for filings. Content includes disclosures. For our tort claim, I’ll search “Ebro Foods risk,” to find statements, evidencing exposure.
[cnmc.es/](https://www.cnmc.es/) is Spanish competition, with search by study, rules for reports. Content includes analyses. For our expiry review, I’ll search “food supply chain,” to find studies, evidencing market issues.
[transparencia.gencat.cat/](https://transparencia.gencat.cat/) is Catalan transparency, with search by topic, rules for data. Content includes reports. For our findings, I’ll search “palm oil imports,” to find data, evidencing regional impact.
[consultas.oepm.es/](https://consultas.oepm.es/) is Spanish patents, with search by term, rules for filings. Content includes IP. For our expiry review, I’ll search “traceability patents,” to find tech, evidencing options.
[publicadorconcursal.es/](https://www.publicadorconcursal.es/) is Spanish insolvency, with search by company, rules for notices. Content includes filings. For our tort claim, I’ll search “biodiesel importers,” to find financial stress, evidencing harm.
[boe.es/buscar/concursos.php](https://www.boe.es/buscar/concursos.php) is Spanish insolvency, with search by entity, rules for notices. Content includes proceedings. For our findings, I’ll search “food manufacturers,” to find insolvencies, evidencing economic impact.
[contrataciondelestado.es/](https://contrataciondelestado.es/) is Spanish tenders, with search by keyword, rules for notices. Content includes contracts. For our expiry review, I’ll search “satellite monitoring,” to find costs, evidencing budget.
[infosubvenciones.es/](https://www.infosubvenciones.es/) is Spanish subsidies, with search by sector, rules for grants. Content includes data. For our WTO action, I’ll search “agriculture subsidies,” to find comparisons, evidencing distortion.
[registradores.org/](https://www.registradores.org/) is Spanish registries, with search by activity, rules for statistics. Content includes data. For our findings, I’ll search “food sector CNAE,” to find economic data, evidencing impact.
[registradores.org/actualidad/portal-estadistico-registral/estadisticas-mercantiles](https://www.registradores.org/actualidad/portal-estadistico-registral/estadisticas-mercantiles) is for statistics, with search by code, rules for
COCOO.UK WEBPAGES
New insights reveal the critical importance of aligning our legal and media strategies with the EU Deforestation Regulation (EUDR), which imposes stringent due diligence requirements on palm oil imports, creating a dual pressure point alongside trade remedies. The webpage content emphasizes the need to engage Spanish stakeholders, particularly producers, farmers, and consumers, to build a broad coalition for a collective action, highlighting local economic and environmental harms. The Transparency International and FATF documents provide a governance angle, suggesting that our proposed national traceability system in Indonesia can be framed as an anti-corruption and transparency tool, enhancing its appeal to international funders and Indonesian authorities. The complex ownership structures in the palm oil sector, often obscured through offshore entities, underscore the necessity of a robust verification system to ensure compliance with global standards. Additionally, the political sensitivity in Indonesia regarding sovereignty necessitates a diplomatic approach, positioning our solution as a partnership rather than an imposition.
Findings of infringement that allow a follow-on claim include the European Commission’s 2019 determination that Indonesian biodiesel subsidies caused material injury to EU producers, resulting in countervailing duties of 8-18%. This finding, documented in Regulation (EU) 2019/2092, establishes a clear precedent of actionable subsidies under WTO rules, causing adverse effects like price undercutting and lost market share. The US Department of Commerce’s 2017 findings further corroborate this, identifying subsidy margins of 34-64% for major Indonesian producers like Wilmar and Musim Mas, leading to US duties. The EU’s 2023 anti-circumvention investigation, suspecting transshipment through China and the UK, reinforces ongoing infringement concerns. In Spain, the CNMC has not yet investigated these imports as unfair competition, but the webpage suggests that systematic sales below sustainable costs could violate Article 3 of Spain’s Competition Law and the Unfair Competition Law, providing grounds for a national-level claim.
Possible causes of action include a collective tort claim in Spain for unfair competition against importers and distributors who knowingly sold subsidized biodiesel, leveraging the CNMC’s mandate to address market distortions. We could pursue judicial review in the UK if the Trade Remedies Authority (TRA) fails to extend duties, arguing irrationality given evidence of ongoing subsidies and injury. In the EU, we can participate in the EC’s expiry review to advocate for duty continuation, potentially challenging any decision to lift them as contrary to EU interests under Regulation (EU) 2016/1037. A novel action could involve challenging Spanish authorities like MITECO for failing to enforce EUDR due diligence, breaching statutory duties. Additionally, we could explore a WTO complaint against Indonesia for prohibited export subsidies, building on the EU and US findings, though this would be state-led. For private companies, a claim for unlawful means conspiracy could target firms facilitating circumvention, holding them jointly liable with negligent customs authorities.
Evidence and sources include statistical evidence from the European Commission’s 2019 investigation, showing a 7.4% price undercutting by Indonesian biodiesel, sourced from Regulation (EU) 2019/2092 (official EU document). Financial evidence of EU industry losses, estimated at €40 million annually, comes from the same regulation, detailing lost sales and margins. Documentary evidence of US findings, with 34-64% subsidy margins, is sourced from the US Department of Commerce’s 2017 fact sheet. Investigative evidence of circumvention is found in the EU’s 2023 probe notice (OJ C/2023/1038). Qualitative evidence of environmental harm, linking palm biodiesel to deforestation, is drawn from the EU’s Renewable Energy Directive (RED II) and EUDR texts, supported by NGO reports like those from Greenpeace. Local impact evidence in Spain, including plant closures in Castellón and Huelva, is referenced in the webpage’s campaign section (indonesia.cocoo.uk). Internal COCOO documents, such as the Annex Report, provide analytical evidence of market distortions and stakeholder harms.
Search strategies to implement on platforms to seek further evidence include using www-eur-lex to retrieve all EUDR implementing acts and delegated regulations, searching for “Regulation (EU) 2023/1115” and “implementing act” to ensure our traceability system aligns with technical standards. On www-companieshouse, search for UK subsidiaries of Wilmar and Musim Mas using SIC codes for “wholesale of oils” to trace their UK operations and financials. Use www-ec-europa-eu-haveyoursay to download submissions from the EUDR consultation, searching for “palm oil” and “Indonesia” to identify stakeholder objections. On www-globaltradealert-org, search for “EU Deforestation Regulation” to find its classification as a trade barrier, validating Indonesian concerns. Employ www-opencorporates-com to map ownership structures of Indonesian producers, using company names like “Sinar Mas” and filtering for Singapore and Hong Kong entities. On www-violationtracker-uk, search for “Cargill” and “Unilever” under “environment-related offences” to build compliance profiles. Finally, use www-wto-disp-settlement to analyze DS655 and DS593 case documents, searching for “Indonesia biodiesel” to extract legal arguments and injury findings.
This comprehensive strategy leverages robust evidence and legal grounds to pursue compensation and systemic solutions, ensuring COCOO’s success in protecting fair competition and sustainability in the biodiesel market.
COAS & FOIS
As COCOO’s solicitor, my mission is to secure the continuation of anti-subsidy measures on Indonesian biodiesel imports to protect our client’s interests in the EU biodiesel market. Here’s how I’ll approach it:
The case centers on the European Commission’s review of countervailing duties imposed in 2019 on Indonesian biodiesel, which is subsidized and harms EU producers like COCOO. My strategy involves gathering evidence, participating in reviews, and ensuring fair competition. Here’s the breakdown:
First, the possible causes of action include actively participating in the EC’s expiry review by submitting evidence of ongoing subsidies and potential injury, engaging with the UK’s Trade Remedies Authority for their parallel review, and working with national authorities like Spain’s CNMC to address market distortions. We’ll also monitor for duty circumvention to strengthen our case.
Findings of infringement show that in 2019, the EC found Indonesian subsidies caused material injury, leading to duties of 8-18%. The US imposed similar measures, and there’s an ongoing WTO dispute by Indonesia, with investigations into duty circumvention via China and the UK, highlighting persistent issues.
Insights reveal maintaining duties is crucial to protect COCOO from unfair competition, especially with environmental regulations like the EU Deforestation Regulation impacting imports. The growing EU biodiesel market, projected to reach USD 32.2 billion by 2033, is vulnerable without protection.
To make money from this case, I’ll charge fees for legal services, including preparing submissions and representing COCOO in reviews, advise on compliance with trade and environmental laws to bolster market position, and potentially explore success fees if duties are maintained, enhancing COCOO’s profitability.
This approach ensures we win by safeguarding COCOO’s market share and competitiveness, leveraging all available legal avenues and evidence.
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Key Citations:
– European Commission Notice on Biodiesel Duties [C/2024/7405](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L:2024:018:FULL)
– Legal Analysis on Indonesian Biodiesel Subsidies [Attachment 16 Analysis]([invalid url, do not cite])
– IEA Report on Transport Biofuels [Renewables 2023 Analysis](https://www.iea.org/reports/renewables-2023/transport-biofuels)
– Reuters on EU Probe into Indonesian Biodiesel [EU Investigation 2023](https://www.reuters.com/business/energy/eu-probe-if-indonesia-circumventing-biodiesel-import-duties-2023-08-17/)
– USDA on Indonesian Biofuels [Biofuels Annual 2024](https://apps.fas.usda.gov/newgainapi/api/Report/DownloadReportByFileName?fileName=Biofuels%2BAnnual_Jakarta_Indonesia_ID2024-0018.pdf)