By: Andra Tofan, Oscar Zou, & Jenik Radon

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The invasion of Ukraine by Russia, an energy powerhouse, has woken the EU up to the inevitable truth that (over)dependence on other countries’ supplies based on mere economic necessity is not only unwise but risky in the long run. As the European Commission’s President Ursula Gertrud von der Leyen declared, “[t]he European Union has therefore decided to . . . turn towards more reliable, trustworthy partners.”^[1] Two questions naturally arise. First, what does “reliable and trustworthy” mean? Second, how do we ensure partners stay “reliable and trustworthy” in the long run?^[2]

We have previously seen the EU’s commendable attempts at introducing values-based agreements in high-stakes negotiations with its trade partners, notably the trade part of the EU-Mercosur Association Agreement and the EU-China Comprehensive Agreement on Investment.^[3] Despite this positive shift, will the EU remain committed to its “values-based trade agenda” amid the greatest energy crisis the block has ever faced?^[4]

We hope that the EU has learned its lesson by continuing to diversify gas suppliers. However, even in the face of the current gas crisis, the EU should rethink gas supply agreements as not only values-based agreements that touch upon Sustainable Development Goals (“SDGs”),^[5] such as climate action and affordable and clean energy, but also as opportunities to commit trading partners to the concrete implementation of those goals. Otherwise, reliability and trustworthiness will only produce short-term economic security, and true long-term partnership will be all but another illusion.

Two recent gas deals offer insights into the likelihood of this happening, and this article explores both of these deals below. To begin, there is the tripartite natural gas export deal among the EU, Egypt, and Israel, whereby Israel would export gas to Egypt, which would be liquified and re-exported to Europe as liquified natural gas.^[6] Then, there isthe gas export deal between the EU and Azerbaijan, by which Azerbaijan exports gas to Europe through the Trans-Adriatic pipeline.^[7]

The EU has signed Memorandums of Understanding (“MoUs”) with all three trade partners. However, these MoUs disappointingly fall short of the values-based standards the EU prides itself in implementing in its trade agreements.

EU, Egypt, and Israel

The signing of the Memorandum of Understanding between the EU, Egypt, and Israel (“EU-Egypt-Israel MoU”) in Cairo on June 15, 2022, was celebrated as “a big step forward in the energy supply to Europe” and a continuous commitment by Egypt and Israel to “help [the EU] with the energy crisis.”^[8] On its face, the EU-Egypt-Israel MoU appears to be a successful example of a values-based agreement, starting with the reminder that its provisions are underlined by the countries’ (“the Sides”) commitment to the Paris Agreement, EU’s goal to reach climate neutrality by 2050, and the Sides’ clear intention to help one another transition to green energy.^[9] Yet, a closer look at the EU-Egypt-Israel MoU’s provisions leaves one wondering why this vision is not reflected as actual commitments in its provisions.

Although it is commendable that the EU-Egypt-Israel MoU states that the Sides will be jointly and severally responsible for projects or activities that can cause pollution to the environment through the language “endeavour[ing] to ensure, jointly and severally that . . . activities . . . will not cause pollution,”^[10] the agreement nonetheless falls short of an actual commitment. Let us be frank, to simply endeavour is not a commitment. We cannot accept that in 2023, when we are close to the point of no return after which climate damage becomes irreversible,^[11] the Sides do not take the responsibility of committing to higher and binding standards of environmental protection, especially considering the EU’s pledge towards a values-based agenda. One possibility would be to give third parties a right to sue either the EU-Egypt-Israel MoU’s Sides or the private developers of the projects that caused the environmental damage arising from the activities envisioned by the aforementioned provision, section 3.

This soft language is not only set forth in section 3 but is also applied in section 5 where the parties similarly “endeavour to encourage the Sides’ public and private corporations to cooperate on the means for achieving green energy goals and combatting climate change.”^[12] A true commitment to the goals of the Paris Agreement should have included a binding and enforceable pledge, such as “at least 20% of each Side’s annual national budget on innovation, research, and development shall go towards climate action projects” or “the Sides’ designated public and private sector corporations will meet at least once a year to exchange information and ideas about green energy transition and the development of sustainable energy infrastructure.” 

One could say that such solutions are already included in the EU-Egypt-Israel MoU under section 2(e), which reads that the Sides can “[explore] ways to make funds available, including by the EU to . . . provide . . . knowledge and technologies regarding emissions reduction and natural gas decarbonization.” Nonetheless, exploring ways to make funds available and “[exploring] the possibility of working collaboratively”^[13] both ensure, at most, that the Sides’ representatives might get together from time to time to discuss funding, know-how, and technologies available. In fact, such meeting(s) may simply be nato with a small n­—“no action, talk only.” If nothing is available and the conversation leads nowhere, there is no commitment that the Sides go back to the discussion table and commit to actually finding a way to share funding and information. That is to say that we should feel satisfied with the crumbs, i.e., the feel-good language of mere effort. We maintain that commitment to a values-based trade agenda means that the EU needs to start aligning its actions with its words, everything less is a baseless promise resulting in a gradual but inevitable loss of trust. It is time for the EU to walk the talk.

Section 6 follows on the same lines. Instead of leaving open the possibility of ministers meeting to discuss the renewable energy transition as the Sides deem fit, a next step could have been to conduct a biennial audit of the implementation of the green energy goals committed to under the EU-Egypt-Israel MoU and the subsequently signed agreement. As above, we expected the EU to go one step further if it wants to be true to its public commitment to pursue values-based agreements. For example, if the green energy goals are not met, the EU can be automatically entitled to a 20% reduction of the gas price, cut 20% of the funding allocated for the breaching Side’s green energy projects starting immediately with the next payment, or terminate the agreement altogether depending on Egypt’s and/or Israel’s severity of the lack of progress. Introducing such meaningful provisions, namely provisions with teeth, in the EU-Egypt-Israel MoU from the beginning would have set the stage for subsequent negotiations and would have demonstrated the EU’s unshakable intention to only trade with countries that take their green energy commitments seriously. Besides, such provisions would demonstrate the EU’s courage, integrity, and grit to take all steps necessary to accelerate global action—even terminating the gas trade deal if the other Sides do not meet their proclaimed and committed climate targets.

In light of the above, one unfortunately has to conclude that the EU failed to once again deliver on its promise to lead with a values-based trade agenda. As we have already noted, the EU has failed to walk the talk. We can only hope that the EU continues to have the integrity and internal motivation to take climate action seriously through policies and systems such as the European Green Deal and the EU Emissions Trading System, and by dedicating substantial funding to the cause.^[14] However, when it comes to countries such as Egypt and Israel, what the EU needs to internalize is that soft language, optional commitments, and good faith provisions do not bring about needed accelerated change. The clock is ticking and more needs to be done now.

On a different note, what is even more concerning is the EU-Egypt-Israel MoU’s silence on human rights abuses, despite Egypt’s^[15] and Israel’s^[16] track records as noted by recognized international human rights organizations. Since such abuses breach at least three SDGs (peace, justice, and strong institutions; good health and wellbeing; and reduced inequalities), human rights protections should have been addressed by the EU-Egypt-Israel MoU to some extent.

In summary, we fail to see how the EU-Egypt-Israel MoU lives a values-based trade agenda and gives meaning, real concrete meaning, to the words of the European Commission’s President Ursula Gertrud von der Leyen describing the turn to working with “more reliable, trustworthy partners.”^[17]

EU-Azerbaijan

As the EU-Egypt-Israel MoU demonstrates, the EU’s soft language and silence on aspects of environmental and human rights issues show that in the face of pressing energy demand, the EU has not made effective its own SDGs, let alone attempts to curtail human rights abuses by its trading partners. The danger of such a willingness to forgo even preliminary commitments is arguably more pronounced in the EU’s energy trade with Azerbaijan—a partner that recognized international institutions rank even lower on environmental and human rights issues than Egypt.^[18]

In July 2022, the EU and Azerbaijan signed a new Memorandum of Understanding on a Strategic Partnership in the Field of Energy (“EU-Azerbaijan MoU”), which aims to “double the capacity of the Southern Gas Corridor to deliver at least 20 billion cubic metres to the EU annually by 2027.”^[19] Amazingly, despite the lapse of almost a year, the EU has not yet disclosed the official agreement. Thus, whether the EU has taken firm actions to implement a values-based trade agenda remains a dubious question.

As Azerbaijan President Ilham Aliyev explained, the signed memorandum in July 2022 “follows the previous strategic partnership agreement signed in 2006,” which in fact employs ambiguous terms that render it impossible for parties to be held accountable for the violation of the mentioned commitments.^[20] As the clauses themselves show, Azerbaijan will “endeavour” to cover “optimization of the energy generation with a view to increase . . . environmental safety [and] operational liability . . . .”^[21] Likewise, Azerbaijan will “examine ways to enhance safety and security Azerbaijan transit . . . pipeline network.”^[22] That is to say, regarding the SDGs’ objectives to ensure sustainable production^[23] and to combat climate change,^[24] the clauses never go beyond mere wishes. On the other hand, even in the face of Azerbaijan’s recent human rights abuse issues,^[25] this agreement does not mention the protection of human rights at all. Together, these two facets of the 2006 agreement risk entrusting local authorities with excuses to commit human rights abuses in the names of “operational liability,” “pipeline security,” and “safe human settlement” without placing concrete limitations.^[26] Admittedly, the MoU itself states that it only “records political intent alone and provides no legal commitment.” Yet it also points out that the MoU is a “basis for possible future discussions between the parties.” Therefore, if concerns and intents about environment and human rights are not raised there, will they ever be raised later?

The SDGs were not formed until 2015, and the EU’s willingness to adopt values-based cooperation that touches on human rights concerns was not clear until the 2020 EU-China Investment Agreement. However, the analysis above evinces that the 2022 agreement’s tendency to “follow” its 2006 precedent is itself an alarming sign. This is especially true for human rights abuses, the commission of which by Azerbaijan has frequently raised the EU’s concerns.^[27] As for the energy trade, as an official question submitted to the EU Parliament inquired, “What is the Commission’s response to the fact that . . . Russia scores significantly better (19/100) than Azerbaijan (9/100), both in terms of political rights and civil liberties?”^[28] Admittedly, this ranking was made prior to the Russian invasion of Ukraine. In any case, rather than answering this question directly, the committee responded by pointing out that human rights commitments were already stated in the jointly agreed EU-Azerbaijan Partnership Priorities of 2018, which have been “extended” until 2024.^[29]

Nevertheless, it seems that history is again repeating itself. Among the three occasional mentions of “human rights” in the EU-Azerbaijan Partnership Priorities, willingness regarding “human rights” is never preceded by concrete terms obliging its implementation.^[30] For instance, in the “PRIORITIES” section, the document only provides that “the cooperation will range from good governance [to] human rights.”^[31] As this blog’s early article on the EU-China Investment Agreement observed, “[a]lthough impressive sounding, these are all vague promises that leave many unanswered questions—in fact they raise more questions than they actually give answers.”^[32] Moreover, as the Human Rights Watch also points out, “while the [EU] has signed a deal with Azerbaijan aimed at increasing the country’s gas exports . . . , it failed to set conditions for future cooperation that will help secure rights improvements.”^[33] The “commitments” claimed by the committee, in turn, may not be able to commit, no less bind, either side to their stated goals.

It should be noted that President Macron’s previous stance toward the EU-Mercosur deal is one of championing a world we need, we want.^[34] However, here, from police abuse to total media control and full power consolidation, Azerbaijan President Ilham Aliyev’s leadership can be anything but “reliable and trustworthy.” Thus, the fact that the language employed by problematic documents was merely “extended” does not demonstrate an active and positive attitude towards addressing the above-mentioned concerns and creating a world we need, we want. Rather, it may merely be nato with a small n, “no action, talk only”. In any case, it remains to be seen whether the dedication to values will actually underpin the finalized deal, and if so, in what way. 

Conclusion

What are the values we espouse, believe in, and want? What are the goals? How do we get there? What are the specific standards? What mechanism should the parties adopt to oversee and, hopefully, enforce compliance? Most importantly, how should future energy agreements deter a trading partner from disregarding commitments from the outset if one allows them to treat one-off “penalties” as necessary “parking tickets?” Given the precedents and current happenings, more meaningful and effective ways to ensure the execution of non-economic commitments will be necessary to achieve the long-term stability of the EU’s energy trade, climate change reduction, and SDGs. In short, it is time for trade agreements to walk the talk and not continue to enshrine nato, with a small n, “no action, talk only,” as a governing and enforcement principle. The solutions suggested by this article may seem radical, and overly idealistic at first, but if visions for a world we want and need are not proposed some time and somewhere, they will never be raised later:

1. As aforementioned, the EU can include in its agreements with energy trade partners a clause granting it the power to automatically reduce 20% of the gas price provided that green energy goals are not met by the partner(s) by a specified date. Alternatively, and perhaps more ambitiously, a mechanism that automatically stops the calculation of gas-supply volume between the EU’s discovery of agreement violation and the other side’s official reply can be included in the contract. This will result in a price-reduction effect similar to the one mentioned above. This should incentivize all trading partners to pay more attention to, and take seriously, potential violations of the agreed-upon terms regarding environment, human rights, and other SDGs commitments.
2. Moreover, the EU can take advantage of its preexisting commercial relationship with Egypt, Israel, and Azerbaijan by using it as the basis for imposing penalties and sanctions. For example, a clause can be included in the contract to allow the EU to reduce its export quota with Egypt, Israel, and Azerbaijan for any violation. Since the EU is the countries’ main trade partner,^[35] the inclusion of such a clause may serve as a powerful deterring factor. Likewise, as the European Neighbourhood Policy’s main objective is to “promote key EU interests of good governance, democracy, rule of law and human rights” through the issuance of financial support, the EU may resort to this existing economic connection to deter the other trading partner’s inertness to the execution of environmental and human rights commitments.^[36] Accordingly, depending on the severity of the lack of progress, the EU may be justified to cut at least 20% of its current funding to Egypt, Israel, and Azerbaijan under its European Neighbourhood Policy. 
3. The EU may look to future contracting opportunities for solutions to its trading partners’ potential violation of agreed-upon value-based terms. The EU may, for instance, include a term mandating that if the trading partner grossly violates the agreed upon terms on environment or human rights protection, the EU will not extend the agreement or separately contract with that breaching party for 5 years following the termination date of the current contract. Admittedly, such a move may risk jeopardizing the EU’s own future gas supply by limiting its options. However, considering the huge profit and the existence of various competing supplier nations, existing trading partners such as Egypt, Israel, and Azerbaijan may also be reluctant to risk losing their own opportunities. In fact, the inclusion of such a clause is logically consistent—if the parties have already agreed to the protection of the environment and human rights, there is no rational reason to object to such conditions during the negotiation since the only conditional constraint is the agreed upon terms themselves. 

In light of all this, one cannot but wonder: how can the EU enter into gas supply commitments with countries without incorporating its values, certainly not by continuing to favor nato with a small n, “no action, talk only,” over EU values. Trading with energy rich countries creates a unique opportunity to display the EU’s commitment to values-based trade agreements. Nonetheless, this opportunity has been missed, and so has one’s hope and trust in the EU that the EU will finally accept and embody its center-stage role as implementer of the values-trade agenda. It is time for the EU to align its words with its actions and to walk the talk.

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About the Authors

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^[1] European Commission Press Release STATEMENT/22/4583, Statement by President von der Leyen with Azerbaijani President Aliyev (July 18, 2022), https://ec.europa.eu/commission/presscorner/detail/en/statement_22_4583.

^[2] Just as countries seek to prioritize ‘reliable and trustworthy’ partners in trade agreements, particularly those who uphold human rights, lawyers would similarly benefit from evaluating the reliability and trustworthiness of their clients and dedicate themselves to a standard of ethics that is not merely legal, but one that protects against corruption and abuse.  See Caitlin Parets, Scarlett Del Giudice Boyer, & Jenik Radon, Human Rights and Ethical Lawyering: The Need for a Lawyer’s Hippocratic Oath, Compar. Jurist (June 20, 2023), https://comparativejurist.org/2023/06/20/human-rights-and-ethical-lawyering-the-need-for-a-lawyers-hippocratic-oath/.

^[3] Allison Lofgren & Jenik Radon, EU-China Investment Agreement: A Values Agreement? The Proof Will Be in The Pudding, Compar. Jurist (Jan. 28, 2021), https://comparativejurist.org/2021/01/28/eu-china-investment-agreement-a-values-agreement-the-proof-will-be-in-the-pudding/.

^[4] European Commission Press Release IP/20/2541, EU and China Reach Agreement in Principle on Investment (Dec. 30, 2020), https://ec.europa.eu/commission/presscorner/detail/en/ip_20_2541 [hereinafter Press Release IP/20/2541].

^[5] Sustainable Development: The 17 Goals, U.N. Dep’t Econ. & Soc. Affs., https://sdgs.un.org/goals (last visited May 27, 2023) [hereinafter SDGs].

^[6] Sarah El Safty & Ari Rabinovitch, EU, Israel, and Egypt Sign Deal to Boost East Med Gas Exports to Europe, Reuters (June 15, 2022, 7:26 AM), https://www.reuters.com/business/energy/eu-israel-egypt-sign-deal-boost-east-med-gas-exports-europe-2022-06-15/. 

^[7] Jacob Dick, Initial Expansion of TAP Natural Gas System Launches Bid to Double Azerbaijan Exports to Europe, Nat. Gas Intel., https://www.naturalgasintel.com/initial-expansion-of-tap-natural-gas-system-launches-bid-to-double-azerbaijan-exports-to-europe/. 

^[8] El Safty & Rabinovitch, supra note 5.

^[9] Memorandum of Understanding on Cooperation Related to Trade, Transport, and Export of Natural Gas to the European Union, Egypt-EU-Isr., June 15, 2022, https://energy.ec.europa.eu/system/files/2022-06/MoU%20EU%20Egypt%20Israel.pdf [hereinafter Egypt-EU-Isr. MoU].

^[10] Id. § 3.

^[11] Ivana Kottasová, It’s Getting More Likely the World Will Reach a Climate Tipping Point in the Next Five Years, CNN (May 27, 2021, 9:33 PM), https://www.cnn.com/2021/05/27/world/climate-temperatures-increase-wmo-intl/index.html. 

^[12] Egypt-EU-Isr. MoU, supra note 8, § 5.

^[13] Id. § 2.

^[14] See, e.g., Funding for Climate Action, Eur. Comm’n, https://climate.ec.europa.eu/eu-action/funding-climate-action_en (last visited May 27, 2023).

^[15] Amnesty International has warned the international community “not to be deceived by Egypt’s attempts to conceal the magnitude of the human rights crisis in the country” after a new Amnesty International report revealed that Egypt was using its “National Human Rights Strategy as a shiny cover-up to their unrelenting violations of human rights.” Egypt: Human Rights Crisis Deepens One Year After National Human Rights Strategy Launched, Amnesty Int’l (Sept. 21, 2022), https://www.amnesty.org/en/latest/news/2022/09/egypt-human-rights-crisis-deepens-one-year-after-national-human-rights-strategy-launched/. Human Rights Watch notes that, in 2021, the Egyptian authorities increased the prosecution of peaceful activists and critics.  Moreover, the rights watchdog spotlights Egypt’s continued escalation of “its use of the death penalty and executions, in many cases following unfair proceedings and mass trials.” Egypt: Events of 2021, Hum. Rts. Watch, https://www.hrw.org/world-report/2022/country-chapters/egypt/ (last visited May 27, 2023).

^[16] According to Amnesty International, Israel has exacerbated the humanitarian crisis in Palestine, engaging in unlawful attacks, arbitrary detentions, apartheid, and forced evictions. Israel and Occupied Palestinian Territories 2021, Amnesty Int’l, https://www.amnesty.org/en/location/middle-east-and-north-africa/israel-and-occupied-palestinian-territories/report-israel-and-occupied-palestinian-territories/ (last visited May 27, 2023); see generally Amnesty Int’l, The State of the World’s Human Rights (2022/23). Similarly, “Human Rights Watch has found that Israeli authorities’ systematic oppression coupled with the inhumane acts they have committed against Palestinians . . . amount to the crimes against humanity of apartheid and persecution.” Israel: Collective Punishment against Palestinians, Hum. Rts. Watch (Feb. 2, 2023), https://www.hrw.org/news/2023/02/02/israel-collective-punishment-against-palestinians/. 

Freedom House further notes that “Israel’s military occupation of the West Bank entails onerous physical barriers and constraints on movement, demolition of homes and other physical infrastructure, restrictions on political rights and civil liberties, and expanding Jewish settlements that are widely considered to constitute a violation of international law.” Freedom House, Freedom in the World: West Bank (2023), https://freedomhouse.org/country/west-bank/freedom-world/2023. The West Bank is “not free” according to Freedom House’s weighted assessment of global freedoms, giving the territory a score of 4 out of 40 for political rights and a score of 18 out of 60 for civil liberties. Id. The Gaza Strip is similarly “not free” under the same metrics governed by Freedom House, scoring 3 out of 40 for political rights and 8 out of 60 for civil liberties. Freedom House, Freedom in the World: Gaza Strip (2023), https://freedomhouse.org/country/gaza-strip/freedom-world/2023). 

At the same time, international human rights organizations have found human rights violations committed by Palestinian actors. To note one such example, Freedom House detailed that “Hamas-led authorities [in the Gaza Strip] have applied the death penalty without due process or adequate opportunity for appeals and without the legally required approval from the [Palestinian Authority] president.” Id.

^[17] See Statement by President von der Leyen with Azerbaijani President Aliyev, supra note 1.

^[18] Although both countries were designated “not free” in Freedom House’s 2023 Freedom in the World Report, Azerbaijan scored 2 out of 40 on political rights and 7 out of 60 on civil liberties, whereas Egypt scored somewhat higher on both metrics with 6 and 12 respectively.  See Freedom House, Freedom in the World: Azerbaijan (2023), https://freedomhouse.org/country/azerbaijan/freedom-world/2023; Freedom House, Freedom in the World: Egypt (2023), https://freedomhouse.org/country/egypt/freedom-world/2023. Similarly, the Earth.Org Global Sustainability Index ranked Azerbaijan 46^th, compared to Egypt at 26^th, out of 197 nations in its measure of economic sustainability. Earth.Org, Global Sustainability Index, https://earth.org/global-sustainability/ (last visited May 30, 2023).

^[19] European Commission, Press Release IP/22/4550, EU and Azerbaijan Enhance Bilateral Relations, Including Energy Cooperation (July 18, 2022), https://ec.europa.eu/commission/presscorner/detail/en/ip_22_4550. The Southern Gas Corridor is an existing pipeline that supplies gas from Azerbaijan to Europe, and the 2022 MoU extends the existing gas supply agreement signed in 2006. Id.; see also infra note 20.

^[20] Ilham Karimli, Azerbaijan, EU Sign New Energy Partnership Deal to Increase Gas Supplies to Europe, Caspian News (July 18, 2022), https://caspiannews.com/news-detail/azerbaijan-eu-sign-new-energy-partnership-deal-to-increase-gas-supplies-to-europe-2022-7-18-0/. 

^[21] Memorandum of Understanding on a Strategic Partnership Between the European Union and the Republic of Azerbaijan in the Field of Energy, Azer.-EU, Nov. 7, 2006, https://www.europarl.europa.eu/meetdocs/2009_2014/documents/dsca/dv/dsca_20130321_14/dsca_20130321_14en.pdf [hereinafter 2006 Azer.-EU MoU].

^[22] Id.

^[23] See SDGs, supra note 4 (Goal 12: “Ensure Sustainable Consumption and Production Patterns”), also available at: https://sdgs.un.org/goals/goal12. 

^[24] See SDGs, supra note 4 (Goal 13: “Take Urgent Action to Combat Climate Change and its Impacts”), also available at: https://sdgs.un.org/goals/goal13.

^[25] See, e.g., Hum. Rts. Watch, Azerbaijan, in World Report 54-60 (2023), also available at: https://www.hrw.org/world-report/2023/country-chapters/azerbaijan.

^[26] See SDGs, supra note 4 (Goal 11: “Make Cities and Human Settlements Inclusive, Safe, Resilient and Sustainable”), also available at: https://sdgs.un.org/goals/goal11. 

^[27] See, e.g., European Parliament, Press Release 20180628IPR06823, MEPs List Conditions for New EU-Azerbaijan Deal (July 4, 2018), https://www.europarl.europa.eu/news/en/press-room/20180628IPR06823/meps-list-conditions-for-new-eu-azerbaijan-deal (describing Parliament’s recommendations to negotiators, including conditioning ratification of agreement on Azerbaijan “respect[ing] fundamental EU values and rights”).

^[28] European Parliament, Parliamentary Question E-002756/2022, Human Rights Concerns in Azerbaijan Following the EU-Azeri Gas Deal: Question for Written Answer to the Commission (Rule 138) by Gunnar Beck (July 29, 2022), https://www.europarl.europa.eu/doceo/document/E-9-2022-002756_EN.html.

^[29] European Parliament, Parliamentary Question E-002756/2022(ASW), Answer Given by High Representative/Vice-President Borrell i Fontelles on behalf of the European Commission (Sept. 22, 2022), https://www.europarl.europa.eu/doceo/document/E-9-2022-002756-ASW_EN.html. 

^[30] Recommendation No. 1/2018 of the EU-Azerbaijan Cooperation Council of 28 September 2018 on the EU-Azerbaijan Partnership Priorities [2018/1598], 2018 O.J. (L 265) 18, 19, https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A22018D1598. 

^[31] Id.

^[32] Lofgren & Radon, supra note 2.

^[33] Azerbaijan, Hum. Rts. Watch, https://www.hrw.org/europe/central-asia/azerbaijan  (last visited May 30, 2023).

^[34] Michalis Polygiannis & Jenik Radon, A Trade Agreement with a Possible Twist: The EU-Mercosur Agreement, Compar. Jurist (Jan. 28, 2021), https://comparativejurist.org/2021/01/14/a-trade-agreement-with-a-possible-twist-the-eu-mercosur-agreement/. 

^[35] For facts and figures regarding the EU’s trade relations with Egypt, Israel, and Azerbaijan, see EU Trade Relationships by Country/Region, Eur. Comm’n, https://policy.trade.ec.europa.eu/eu-trade-relationships-country-and-region_en. 

^[36] Joint Communication to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions, Review of the European Neighbourhood Policy, at 5, JOIN (2015) 050 final (Nov. 18, 2015), https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52015JC0050&qid=1685495360729.

Cover Image: ShotbyDave, Oil Worker Handshake Stock Photo, iStock by Getty Images (Apr. 5, 2014), https://www.istockphoto.com/photo/oil-worker-handshake-gm482927701-37982958.