In February 2024, the United Nations Environment Assembly, UNEA-6, took a significant step toward addressing the challenge of environmental scars of armed conflict. UNEA-6, held in Nairobi, Kenya, aimed to tackle the planet’s most pressing environmental issues – a complex web of problems often referred to as the "triple planetary crisis". This crisis encompasses climate change, the alarming rate of biodiversity loss, and the ever-growing problem of pollution and waste. By recognising the environmental toll of armed conflicts as a key contributor to these crises, UNEA-6 marked a turning point by strengthening international efforts to mitigate the environmental damage caused by war.
But first, let’s take a look at UNEA. As the planet's only universal membership forum for the environment, UNEA is a unique platform that goes beyond just being a decision-making body. Here, world governments, civil society groups, the scientific community, and the private sector can come together. Unlike conferences focused solely on climate change or biodiversity, UNEA stands out from other environmental meetings by taking a holistic approach, allowing participants to address complex environmental challenges as interconnected systems, and avoiding getting bogged down in isolated issues. By breaking down sectoral barriers, this unique space also fosters collaboration across disciplines to develop solutions with broad support, facilitating "courageous decisions and new ideas" to chart a bold plan for collective environmental action. This year's focus on environmental protection during armed conflicts raised awareness on a global scale, paving the way for concrete actions to address this previously neglected issue.
The Nexus Between Conflict and Environment
Recent conflicts highlight the complex relationship between the environment, conflict, and ultimately, peace and security. Armed conflicts can inflict devastating damage on ecosystems, jeopardising both human and ecological well-being. Military activities often lead to environmental pollution, with explosives, heavy machinery, and burning military infrastructure contaminating air, water, and soil with pollutants like heavy metals and toxins. Habitat destruction occurs through deforestation for military bases, bombings, and the displacement of populations disrupting and destroying natural habitats. Armed conflicts not only wreak havoc on human communities but also severely impact animal populations. They lead to death or the disruption of their natural behaviors, such as disrupting their migration patterns. Additionally, the competing demands for resources such as water and timber during these conflicts further contribute to unsustainable exploitation, exacerbating environmental challenges and endangering wildlife.. Recognizing this, addressing the often overlooked environmental and ecological fallout of warfare becomes imperative. The ripple effects extend far beyond the immediate zones of conflict, influencing the foundations of regional stability and ecological sustainability.
Environmental damage in Ukraine
The war in Ukraine has led to profound environmental consequences, affecting a broad spectrum of ecosystems and sectors. Key impacts include severe damage to industrial and energy infrastructure, leading to pollution; threats to nuclear safety due to the conflict's proximity to nuclear facilities; widespread destruction within urban environments from explosive weaponry, generating significant debris and affecting air and land quality; detrimental effects on rural landscapes through fires and damage to agricultural systems, impacting food security; disruptions to freshwater resources and infrastructure, causing water pollution and supply issues; risks to coastal and marine ecosystems from pollution and altered maritime activities; and complex implications for global climate policies due to changes in energy production and consumption.
Damage to critical infrastructure can have devastating short- and long-term consequences for the environment. Before the invasion, Ukraine had a significant industrial base, including 15 nuclear reactors, over 1,600 chemical and pharmaceutical companies, and 148 coal mines; now, Russian attacks have destroyed gas pipelines, caused gas leaks and fires, and bombarded major power plants. The destruction of these facilities has had a profound impact on the environment, with gas leaks polluting the air, endangering human health and harming biodiversity. On a local level, gas leaks are a major cause of smog, aggravating asthma and other respiratory illnesses. These leaks may also contribute to climate change by depleting the ozone layer and worsening global warming.
Vast areas of Ukraine were contaminated with landmines and unexploded ordnance, hindering agricultural production and posing a long-term threat to human, animal, and land health. Many of the environmental and climate consequences will also transcend national borders, affecting neighbouring countries and posing serious health risks to their populations. To fully understand the impact of armed conflict on the environment, we must therefore consider both ecological and climate damage.
Russian missile attacks in the Chernihiv region have caused ammunition depots to explode, contaminating the land and groundwater with heavy metals and other pollutants. These pollutants come from destroyed military supplies, exploding missiles, and air bombs. The situation is further worsened by the forced closure of coal mines, which are now overflowing with acidic wastewater; without proper infrastructure to pump it out, this contaminated water will continue to pollute the water table for years to come. Furthermore, Ukrainian authorities report that over 136,000 explosive devices were defused between February and June 2022 alone, adding to the environmental burden of the conflict.
While this list is far from being exhaustive, it gives an idea of how severely armed conflict can impact the environment. Although these repercussions have always existed, the heightened awareness surrounding them stems from a growing recognition of the importance of environmental protection, combined with advancements in environmental monitoring and the rapid dissemination of news through social media. These challenges, compounded by the need to adapt legal and regulatory frameworks in response to the war, underscore the importance of integrated recovery efforts to address the multifaceted dimensions of environmental degradation and ensure sustainable reconstruction. Whilst attention to these issues in Ukraine is increasing, it is far from the only scene where armed conflicts severely damage the natural environment.
Environmental damage in Gaza
Amidst the humanitarian disaster and the extensive bombings that have claimed thousands of lives, the war in Gaza has triggered a catastrophic environmental crisis, casting a long shadow over both the region's ecological and human health. Beyond the immediate toll on human life, the conflict has devastated Gaza's natural resources, sparking concerns about the long-term viability and sustainability of the environment. The conflict has led to the unprecedented destruction of agricultural land, vital to Gaza's economy and food security. Satellite imagery and reports from the ground indicate that between 38 to 48% of Gaza's tree cover and farmland have been destroyed. The decimation of olive groves, farms, and greenhouses not only halts food production but also poses a significant threat to the region's biodiversity and ecological balance. The loss of vegetation cover exacerbates climate change effects, reducing the area's capacity to sequester carbon and regulate the local climate. Additionally, the heavy use of munitions and the resulting debris have contaminated soil and groundwater with hazardous materials, including heavy metals and unexploded ordnance, affecting long-term soil health. This presents immediate dangers to human health and threatens future agricultural productivity, perpetuating a cycle of environmental degradation and food insecurity.
Water pollution has become a critical issue, directly affecting human health and leading to a complex humanitarian crisis. The destruction of waste management and sewage treatment infrastructure, exacerbated by siege conditions, has resulted in over 100,000 cubic meters of untreated sewage being discharged daily into the Mediterranean Sea. This not only endangers marine life but also human health, as polluted waters contaminate local food chains and drinking water sources. The public health crisis worsens as contaminated water becomes a breeding ground for pathogens, increasing the occurrence of diseases such as cholera, dysentery, and typhoid. Moreover, the widespread burning of waste, the use of alternative fuels, and emissions from military actions have significantly deteriorated air quality. This toxic air has led to an increase in respiratory illnesses among Gaza's residents, exacerbating the public health crisis. Long-term exposure to air pollution poses serious health risks, underscoring the need for immediate actions to improve air quality and protect public health.
The conflict has generated millions of tonnes of debris, much of it contaminated with hazardous substances like asbestos and heavy metals, posing a massive waste management challenge. The cleanup and safe disposal of this debris are crucial to preventing further environmental contamination and ensuring the safety of Gaza's residents. The war in Gaza underscores the urgent need for international cooperation and adherence to environmental and humanitarian laws, highlighting how environmental and climate protections are deeply intertwined with the laws of armed conflict. The classification of environmental destruction as "ecocide" and its investigation as a potential war crime highlight the gravity of the situation. Comprehensive assessments and robust remediation efforts are vital for mitigating the environmental impacts of the conflict and laying the groundwork for the sustainable recovery and resilience of Gaza's environment and communities.
Examples of such links are unfortunately not lacking. The conflict in Tigray, Ethiopia, has caused widespread deforestation for firewood and construction, endangering fragile ecosystems, and increasing the risk of landslides and floods. Decades of civil war in Sudan have disrupted traditional land management practices, leading to desertification and water scarcity, further fuelling conflict and displacement. These are just a few examples of how armed conflicts exacerbate environmental challenges; by understanding this complex relationship, we can develop more sustainable solutions for both environmental protection and peacebuilding.
Evolution of the regulatory framework
The intricate relationship between conflict and the environment is a relatively recent focus within the domain of international humanitarian law. Burgeoning over the past fifty years, explicit treaty rules have emerged in an attempt to safeguard the environment against the ravages of armed conflict. While this evolution reflects a growing awareness of the profound connections between ecological sustainability, human health, and the diverse threats armed conflicts pose to environmental integrity, the development, amelioration, and implementation of contextually sensitive, effective responses is far from being a linear or expeditious process.
Historically, environmental protection during armed conflict was not explicitly addressed within IHL until the latter part of the 20th century. However, significant advancements have since been made, notably through the efforts of the ILC and the adoption of its Principles on the Protection of the Environment in Relation to Armed Conflicts. These principles, welcomed by a UNGA resolution in December 2022, alongside the ICRC's 2020 publication of guidelines for protecting the natural environment in armed conflicts, signify pivotal steps in expanding the scope of environmental protection in war times.
The legal foundation for preventing environmental harm during armed conflict is deeply rooted in international environmental law, emphasising a proactive obligation to prevent such harm before its occurrence. This obligation is critical given the potential magnitude of environmental damage associated with armed conflict, necessitating an understanding that the general preventive obligations found in international environmental law can illuminate similar obligations under the law of armed conflict.
Notable historical incidents of environmental damage related to armed conflict, such as the use of Agent Orange during the Vietnam War, the destruction of oil wells in Kuwait, and the release of hazardous substances in Kosovo, underscore the contemporary relevance and foresight required in preventing environmental harm. The invasion of Ukraine by Russia further highlights ongoing concerns, with environmental destruction occurring through both direct attacks and collateral damage, as above-mentioned.
The regulatory framework protecting the environment in instances of armed conflict is bolstered by a series of multilateral treaties, each with its obligations and scope. The Draft Principles on the PERAC, for example, aim to emphasise the preventive obligations under the LOAC toward environmental protection. The substantive protection of the natural environment under LOAC, particularly within the AP I, underscores a legal obligation to take care during military operations to protect the environment, recognising it as a civilian object entitled to protection.
Summarily, the LOAC's environmental provision encompasses the obligation to avoid unnecessary suffering and destruction, including the prohibition of warfare methods expected to cause widespread, long-term, and severe environmental damage. The Rome Statute of the International Criminal Court further includes the intentional targeting of the environment as a war crime, highlighting the need for preventive measures to avert such outcomes. Notably, the obligation to prevent harm under the LOAC is distinguished from the obligation of care, emphasising a combined force of conduct and result obligations that incorporate aspects of due diligence. This advanced level of obligation underscores the critical nature of preventing severe environmental harm, going beyond mere care to encompass proactive and preventive measures.
Further, the interplay between IEL and the LOAC offers a complementary approach to enhancing the protection of the environment in relation to armed conflict. The principle of lex specialis, mutual supportiveness, and the adoption of a holistic view of environmental protection across different phases of conflict underscore the importance of a comprehensive approach to preventing environmental harm. Moreover, the obligation to prevent war crimes under the LOAC, viewed through the lens of IEL, provides an avenue for extended environmental protection, necessitating measures to prevent anticipated environmental harm. This obligation, characterised by its ongoing nature, mandates continuous efforts to prevent, reduce, and eliminate environmental damage, reflecting a commitment to safeguarding the environment before, during, and after armed conflicts.
The UNSC, responsible for international peace and security issues, has the mandate to address this "environment-conflict nexus". While it issued resolutions on specific situations, the Security Council has not adopted a general resolution on environmental protection during conflicts. Such a resolution is crucial, especially considering the current environmental crisis. The Security Council's binding nature and enforcement capabilities could significantly improve the legal framework protecting the environment during wartime. However, the Council's mandate, structure, and manner of operation create obstacles to adopting such a thematic resolution.
Liability in environmental damages
The debate on liability for environmental damage in armed conflicts underscores a complex intersection of legal, ethical, and practical challenges. As armed conflicts continue to evolve, so too does the recognition of the need for robust mechanisms to address the environmental devastation they leave in their wake. The historical backdrop of mining conflicts, international environmental liability principles, and the specific challenges of addressing environmental damage during armed conflict highlights the struggle to find a balance between economic development, environmental justice, and the legal mechanisms to enforce liability.
One of the most illustrative examples of the attempts to address this challenge is the establishment of the UNCC following the 1991 Gulf War. The environmental catastrophe resulting from this conflict – notably, the deliberate destruction of Kuwaiti oil wells – necessitated an unprecedented approach to environmental liability and compensation. The UNCC was tasked not only with compensating for personal and financial losses, but also with addressing the significant environmental damage caused.
The UNCC’s mandate to process claims and compensate for losses directly resulting from Iraq's invasion of Kuwait introduced a novel approach to international environmental liability. This included compensation for "F4" claims, specifically targeting environmental damage and depletion of natural resources. The approach taken by the UNCC to assess and award compensation for these claims provides valuable insights into the practical application of international environmental liability norms in the context of armed conflict.
The operationalisation of the UNCC involved a meticulous process of claim categorisation, assessment by expert panels, and strict oversight of compensation use. This meticulous process underscored the challenges of quantifying environmental damage, requiring precise estimates, detailed costs, and clear scientific evidence. Moreover, the difficulty of placing a monetary value on the environment, coupled with the debates over the quantity and quality of evidence, highlighted the inherent challenges in enforcing liability for environmental damage.
Despite these challenges, the recognition of F4 claims and the subsequent compensation awarded for remediation and restoration efforts represent a significant step in acknowledging the need for environmental protection during armed conflicts. The UNCC’s process and the challenges encountered underscore the complexities of establishing clear liability and effective redress mechanisms. However, the commission's work also demonstrates the potential for international mechanisms to contribute to the restoration of environmental damage caused by armed conflicts.
The closure of the UNCC, having processed approximately 1.5 million claims and awarded US$52.4 billion in compensation, marked a significant moment in the evolution of international environmental liability. The resolution adopted by the Governing Council, declaring that the Government of Iraq had fulfilled its international obligations, underscored the potential for structured compensation mechanisms to address environmental damage in the aftermath of conflict.
This evolving legal discourse took a significant step forward with the adoption of the 2022 draft principles on the protection of the environment in relation to armed conflicts. These principles underscore the urgent need to safeguard the environment before, during, and after armed conflicts. Among these principles, a notable emphasis is placed on state responsibility, asserting that an internationally wrongful act by a state in the context of an armed conflict that results in environmental damage entails an obligation for full reparation, including to the environment itself. This encompasses the development and implementation of measures by states and international organisations to prevent, mitigate, and remediate harm, signifying a paradigm shift towards a more comprehensive and accountable approach to environmental protection in the context of armed conflict.
The principles advocate for enhanced protection through legislative, administrative, and other measures, highlighting the importance of peacekeeping efforts, the designation of protected zones, and the sustainable use of natural resources during occupation. Moreover, they acknowledge the specific vulnerabilities of indigenous peoples and the ecosystems they inhabit, mandating appropriate protective measures. As the international community continues to grapple with the legal, ethical, and practical implications of armed conflict on the environment, these principles offer a foundational framework for advancing the environmental rule of law and ensuring the resilience and recovery of ecosystems impacted by warfare.
As such, the liability for environmental damage during conflicts presents a multifaceted challenge that intersects legal, ethical, and environmental considerations. The UNCC serves as a precedent for addressing such challenges, offering lessons for the development of future mechanisms to ensure accountability and the restoration of environmental damage, whilst the PERAC Principles offer a legal framework to ascertain accountability. The debate on liability thus continues to evolve, reflecting the ongoing search for effective frameworks that balance the need for environmental protection with the realities of armed conflict and international law.
The nexus between conflict and the environment, framed within the evolving regulatory framework, underscores the critical need for a proactive and preventive approach to environmental protection in times of armed conflict and explains the UNEA’s resolution to extend the mandate of UNEP. The development of international legal norms reflects a growing recognition of the importance of safeguarding environmental integrity against the backdrop of warfare, emphasising the interdependence of ecological sustainability and human well-being. Although the legal framework addressing these concerns is slowly evolving, the operationalisation and application of these norms still needs to catch up; this is where the UNEA-6 resolution is innovative.
UNEA-6 Resolution Overview
UNEA-6 culminated in a ministerial declaration emphasising the need for effective, inclusive, and sustainable multilateral action to address climate change, biodiversity loss, and pollution. The declaration acknowledged the threats posed by these global environmental challenges to sustainable development and human health. However, whilst the impact on food security and the worsening effects of poverty and inequality – key drivers of conflicts – are recognised as important impacts of climate change, the notion of armed conflict as such is absent from the final declaration.
Overall, the assembly adopted 15 resolutions covering a wide range of environmental topics, including managing chemicals and waste, the environmental impact of minerals and metals, combating sand and dust storms, regulating highly hazardous pesticides, and the resolution most relevant to this analysis – UNEP/EA.6/RES.12 on environmental assistance and recovery in areas affected by armed conflict. This resolution emerged from a proposal by Ukraine, highlighting the urgency of addressing the environmental consequences of war. Notably, it advocates for a multi-pronged approach aiming to strengthen UNEP's role in assisting conflict-affected regions with environmental recovery efforts.
The UNEP is already active in helping communities in conflict zones via support in natural resources management and the limitation of environmental fallout. It mostly provides science-based advice at the country level. In addition to this scientific scope, UNEP is now also tasked with delivering environmental technical assistance and recovery during armed conflict. This means supporting states in the development and implementation of legal, institutional, and policy measures in response to major environmental challenges. For instance, in 2021, the UNEP provided technical and legal expertise in reviewing Afghanistan's environmental law framework, and gave recommendations to assist Afghanistan in examining several sectors of environmental law.
Under the current resolution, the UNEP will need to identify and develop technical guidance, including new and emerging practices. By establishing a standardised method for measuring environmental damage, the resolution can provide a clearer picture of the devastation caused by war. This data can be used to inform more effective environmental restoration efforts, prioritise resource allocation, and potentially hold perpetrators accountable for ecological harm.
Environmental assistance and recovery will be added to the UNEP Medium-Term Strategy for the next programming period 2026-2029. Given environmental assistance and recovery in armed conflict will receive a dedicated budget, operational team and structure, this is a highly anticipated section. Further, the resolution's acknowledgement of the PERAC Principles, as above-explained, lends further credence to the importance of these forthcoming guidelines. However, this means that before 2026, it is highly unlikely to see concrete operationalisation of this resolution, although the first guidance notes should give an umbrella understanding on how broadly these will be adopted.
Challenges and Oppositions to the PERAC Principles
The PERAC Principles have generated considerable debate, reflecting divergent views among states on the need for, and the scope of, enhanced environmental protection in conflict settings. Several overarching themes emerge from this discussion, highlighting the complexities of integrating environmental concerns within the framework of IHL, IEL, and human rights law.
Firstly, the absence of a universally accepted definition of "the environment" underlines a fundamental challenge, with the term's evolving interpretation reflecting a tension between traditional IHL perspectives and broader environmental considerations. This debate is emblematic of deeper disagreements over whether to retain the specificity of terms like "natural environment," as used in existing IHL texts such as the AP I that argue for consistency of terminology, or to adopt a more inclusive understanding of environmental protection.
Secondly, the normative status of the draft principles has been a point of contention. Questions arise regarding whether these principles merely encapsulate existing obligations or aim to progressively develop international law. Several principles are designed to reflect customary international law, yet not all states recognise this customary status. The divergent views on this matter, as evidenced by the submissions from various states, underscore the delicate balance between codifying existing norms and proposing new directions for the law.
Moreover, the applicability of IEL and human rights law during armed conflicts remains contentious. Some states resist the incorporation of these bodies of law into the PERAC framework, fearing it could complicate the application of IHL. Arguments arising preconise an application on a case-by-case basis, while others welcome the holistic approach, emphasising the benefits of integrating environmental and human rights considerations throughout the conflict cycle.
The opposition to differentiating between international and non-international armed conflicts within the PERAC principles further reflects a conservative stance. This resistance challenges the principles' ambition to provide comprehensive coverage across various conflict scenarios, underscoring the difficulties of aligning the principles with existing legal frameworks.
The role of non-state actors in environmental protection during conflicts has also elicited mixed reactions. While some states advocate for clearer guidance on the responsibilities of non-state armed groups and business enterprises, others caution against broadening the scope of the principles to include these actors, reflecting a wariness of expanding legal obligations beyond state actors. Negotiations also encountered resistance from some states regarding the extent of their accountability. Some states raised concerns over the possibility of a state being held responsible for environmental damage resulting from actions that were in compliance with IHL. They also pointed out that such responsibility might be activated by violations of IEL or human rights laws during conflicts, despite viewing IHL as the more specific legal framework applicable.
Despite these hurdles, a consensus was ultimately achieved. The final resolution, while less ambitious than the initial proposal, still represents a significant step forward, paving the way for more informed future actions, and strengthening the potential to hold parties accountable for environmental destruction during wartime.
Debates in Europe
EU member states have demonstrated varied positions on the PERAC principles, reflecting the spectrum of legal philosophies and priorities within the Union. Belgium, Spain, and the Nordic Countries (Denmark, Finland, Iceland, Norway and Sweden) have shown support for a broader interpretation of environmental protection, advocating for the use of "environment" over "natural environment" to capture the evolving understanding of environmental law. This stance aligns with a progressive outlook, recognising developments in international law that extend beyond the confines of IHL.
Conversely, countries like France and the UK have expressed reservations, particularly regarding the consistency and clarity of terms drawn from IHL. Their emphasis on legal certainty and adherence to existing frameworks reveals a preference for a more cautious approach to integrating new environmental norms into the lexicon of armed conflict law.
The discussion on the normative status of the draft principles has seen a range of responses. While Portugal, Sweden and Finland perceive the principles as a balanced blend of codification and progressive development, others like Germany and the Netherlands have called for clearer distinctions between binding obligations and recommendations. This debate highlights the ongoing struggle to define the legal force and ambition of the PERAC principles.
Moreover, the incorporation of IEL and human rights law into the PERAC framework has been met with both enthusiasm and scepticism. Ireland, Portugal, and the Nordics endorse the inclusion of these legal domains, seeing them as complementary to IHL and essential for a comprehensive approach to environmental protection. In contrast, France, Belgium and the UK have questioned the integration of IEL and human rights law into the armed conflict context, illustrating a concern for the potential complications this might introduce.
On the differentiation between types of armed conflicts, there is a notable divide. While some states advocate for uniform application of the principles to both international and non-international conflicts, others, echoing concerns about consistency with AP I and the potential for legal expansion, have voiced objections. This division underscores the broader challenges of updating and harmonising the legal frameworks governing armed conflicts to address environmental protection comprehensively.
The positions of EU member states on the PERAC principles reflect a complex interplay of legal conservatism, progressive aspirations, and practical considerations. The diversity of views underscores the challenges of forging a consensus on how best to integrate environmental protection into the law of armed conflict, balancing the need for innovation with respect for established legal norms.
The discussion surrounding the European Union's stance is fascinating to examine. At the time of publication, there appears to be no consensus among member states, making it too early to anticipate a cohesive European Union position on the PERAC. It is, however, interesting to note that the EU has developed a comprehensive framework to address the intertwining challenges of climate change, environmental degradation, and security, as articulated in the joint communication, "A new outlook on the climate and security nexus". This approach is browsing on another outlook, not looking at environmental degradation caused by armed conflict, but rather, recognising that climate change and environmental degradation pose significant risks to international peace and security, exacerbating food security issues, instrumentalisation by armed groups, migration, health impacts, and geopolitical tensions in regions like the Arctic and maritime domains.
Whilst these risks are multifaceted, we can notice some similarities in the approach. The EU's strategy is anchored in evidence-based analysis and foresight, emphasising the importance of integrating climate and environmental factors into security and defence planning and operations. Illustratively, it proposes the establishment of a Climate and Environment Security Data and Analysis Hub within the European Union Satellite Centre (SatCen) to enhance the availability and access to data and analytics on climate and security risks.
In summary, priority must clearly be given to operationalising the climate and security nexus across EU external actions, with a focus on embedding these considerations in conflict, crisis, peacebuilding, and post-conflict recovery efforts. This includes integrating climate and environmental aspects into the mandates of EU civilian and military missions and operations and developing capacities for environmental consultation and footprint reporting.
Looking Ahead
The UNEA-6 resolution sets the stage for some key deliverables in the coming years. One crucial outcome is a mandatory report by UNEP outlining its past activities in environmental assistance and recovery for conflict zones. This highly anticipated report will ensure transparency and accountability in the implementation of actions and the evolution of best practices. Further, the debates surrounding the applications will inevitably lead to case laws and rulings, shaping what will become customary applications in the future.
Under the watchful eye of its member states, the UNEP will need to rethink its approach to conflict and environment, underscoring the potential obstacles ahead. Striking the right balance between technical proficiency and the political dynamics of member states will be essential to ensure that the guidance is strong and effective. However, given the intense international focus on ongoing conflicts in places like Gaza, Ukraine, South Sudan, and Ethiopia, initial implementations could face significant challenges.
To keep track of all these advancements, the UNEP must report back to UNEA-7 on the progress made in the development of technical guidelines and the implementation of environmental assistance.