国际商会国际仲裁院-国际商会竞争法和可持续性协议实用指南（英）

PRACTICAL GUIDE COMPETITIONLAW ANDSUSTAINABILITYAGREEMENTS iccwbo.org/TheBusinessOfClimateHigh-level guidance on the application of competition law to sustainability agreements in the European Union, United Kingdom, United States and moreNovember 2025 | Practical guide: Competition law and sustainability agreements | 02DisclaimerThis document provides high-level insights only and has not been reviewed or approved by any regulatory or supervisory authority. Such authorities may take different approaches to the issues discussed.This document does not purport to contain full, accurate, or complete information required to evaluate individual circumstances and is provided strictly on the basis that no reliance should be placed on it for any purpose. Formal legal advice is recommended before entering into any restrictive agreement.The International Chamber of Commerce (ICC) does not assume any duty, responsibility or liability in relation to the contents of this document, including its accuracy, fairness or completeness.Copyright © 2025 International Chamber of Commerce (ICC) ICC holds all copyright and other intellectual property rights in this collective work, and encourages its reproduction and dissemination subject to the following: • ICC must be cited as the source and copyright holder mentioning the title of the document, © International Chamber of Commerce (ICC), and the publication year. • Express written permission must be obtained for any modification, adaptation or translation, for any commercial use, and for use in any manner that implies that another organisation or person is the source of, or is associated with, the work. • The work may not be reproduced or made available on websites except through a link to the relevant ICC web page (not to the document itself). Permission can be requested from ICC through ipmanagement@iccwbo.org .November 2025 | Practical guide: Competition law and sustainability agreements | 03Table of contentsA. Introduction ....................................................................................................04B. Competition law and sustainability agreements: European Union and United Kingdom .....................................................05Prohibited agreements .................................................................................... 05Agreements unlikely to infringe antitrust law .................................................. 06Agreements that require in-depth assessment ............................................... 06C. Competition law and sustainability agreements: United States .....08Sustainability agreements .............................................................................. 08Sustainability standards ................................................................................. 09Information sharing agreements ......................................................................10Advocacy group and trade association meeti