Guidelines on CSDDD

508 submissions in the snapshot (493 from organisations), portal total 508. Feedback list on the portal.

220 of 493 organisation submissions analysed; the model reads them as: opposes 5 supports 30 wants changes 149 36 held back for review (low confidence). 273 without readable text, so not analysed.

• Danish Industry (DI) Business association, DNK; register: Trade and business associations model reads as: wants changes source
  • Conduct a consultation on draft guidelines before final adoption to allow sufficient time for member company input on practical implementation.

    Therefore, we encourage the Commission to conduct a consultation on the draft guidelines prior to their final adoption.

  • Ensure guidelines remain non-binding, non-legislative, and do not expand the scope or obligations set out in the Directive.

    Guidance issued under Articles 18, 19 and 20 should remain non-legislative in nature and should not take the form of Delegated Acts.

  • Adopt a risk-based and outcome-oriented approach emphasizing effectiveness and real impact rather than documentation and administrative compliance.

    The guidance should encourage companies to focus their efforts on preventing and mitigating adverse impacts where they can achieve the greatest effect in practice. To this end, the guidelines should emphasise outcomes and effectiveness rather than documentation requirements, procedural compliance or administrative formalities.

• Österreichischer Gewerkschaftsbund Trade union, AUT; register: Trade unions and professional associations model reads as: wants changes source
  • The Commission should evaluate effective due diligence by its outcomes in preventing and remedying adverse impacts rather than focusing on cost reduction.

    effective human rights due diligence should be evaluated by its ability to identify, prevent and remedy adverse risks to and adverse impacts on rightsholders-not simply by minimising compliance costs.

  • The Guidelines should recognize freedom of association and collective bargaining as severe and highly likely risks across sectors and mandate their assessment across operations and value chains.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • The Guidelines must stipulate that meaningful involvement of worker and trade union representatives is essential across all due diligence steps.

    stipulate that meaningful involvement of worker and trade union representatives is essential to all steps of due diligence on these rights.

• International Federation for Human Rights (FIDH) NGO, FRA model reads as: wants changes source
  • The Commission should ensure considerations of cost-effectiveness do not take precedence over the duty to prevent and remedy human rights and environmental harms.

    considerations of “cost-effectiveness” cannot take precedence over companies’ duty to fully and adequately prevent and remedy the harms suffered by affected individuals and communities resulting from business activities.

  • The Guidelines should emphasize the requirement for companies to meaningfully engage affected and potentially affected stakeholders throughout the due diligence process.

    the Guidelines should insist on the importance for companies to meaningfully engage a wide range of stakeholders, in particular affected and potentially affected persons, in an ongoing, safe and timely manner throughout the due diligence process so as to ensure that the due diligence and remediation measures put in place effectively respond to their needs.

  • The Guidelines should avoid offering one-size-fits-all solutions or fixed lists of references that risk undermining the purpose of mandatory due diligence.

    If the Guidelines were to offer one-fit-all solutions or establish lists of references, this could prove counterproductive and risk jeopardising the very objective of the CSDDD and its due diligence process.

• Bundesvereinigung der Deutschen Arbeitgeberverbände (BDA) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Ensure guidelines remain strictly within the boundaries of the CSDDD and do not create new obligations beyond the Directive.

    The guidelines must not create a second rulebook. It should not introduce new material requirements, broaden the scope of existing obligations or indirectly raise compliance expectations beyond the Directive itself

  • Ensure guidelines are concise, operational and designed for business practitioners with proportionate flexibility for risk prioritization.

    They should therefore be concise, operational and designed for business practitioners responsible for implementation.

  • Avoid including extensive best-practice examples in the guidelines that could be treated as mandatory requirements.

    The Commission should not include extensive best-practice examples in the guidelines.

• Bundesverband Großhandel, Außenhandel, Dienstleistungen e.V. (BGA) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • The guidelines must strictly adhere to the boundaries of the CSDDD without introducing new obligations or expanding the regulatory scope.

    The guidelines must not create a second rulebook. It should not introduce new material requirements, broaden the scope of existing obligations or indirectly raise compliance expectations beyond the Directive itself, e.g. through best practice-examples.

  • The Commission should avoid incorporating extensive best-practice examples that could be misinterpreted as mandatory requirements.

    The Commission should not include extensive best-practice examples in the guidelines.

  • Model contract clauses under Article 18 must remain proportionate, support cooperation, and avoid transferring due diligence burdens or imposing complex obligations on SMEs.

    They should not transfer due diligence obligations from companies in scope to suppliers. In particular, the clauses must avoid disproportionate audit, reporting or information obligations for SMEs.

• Micro company, ALB NGO, ALB model reads as: wants changes source
  • The implementation guidelines should mandate that companies integrate a gender perspective across the entire due diligence process.

    The implementation guidelines should therefore require companies to integrate a gender perspective throughout the due diligence process, including risk identification, assessment, prevention, monitoring and remediation.

  • The guidelines should recognise the critical role of local civil society organisations in supporting companies to identify and assess risks.

    The guidelines should also recognise the essential role of local civil society organisations in supporting companies to identify and assess risks, particularly in supplier countries outside the European Union.

  • Due diligence risk assessments should utilise sex-disaggregated data and track gender-specific indicators.

    Risk assessments should use sex disaggregated data and include indicators related to equal pay, working conditions, gender based violence, access to grievance mechanisms and freedom of association.

• Confederation of Swedish Enterprise Business association, SWE; register: Trade and business associations model reads as: wants changes source
  • The Commission should ensure the guidelines remain non-binding and do not create new obligations, expectations, or administrative burdens.

    It is essential that the guidelines remain clearly non-binding and that they are designed to support companies in their compliance efforts rather than creating new expectations, obligations or administrative burdens.

  • The guidelines must clearly state that due diligence is an obligation of means rather than results and allow companies to prioritise efforts based on risk severity and likelihood.

    The guidelines should clearly manifest that due diligence is an obligation of means (not results).

  • The Commission should conduct a public consultation on the draft guidelines prior to their final adoption.

    We also encourage the Commission to conduct a consultation on the draft guidelines prior to their final adoption.

• UNI Global Union Trade union, CHE model reads as: wants changes source
  • The Guidelines should evaluate human rights due diligence based on outcome effectiveness rather than compliance cost minimisation.

    effective human rights due diligence should be evaluated by its ability to identify, prevent and remedy adverse risks to and adverse impacts on rightsholders-not simply by minimising compliance costs.

  • The Guidelines should establish clear fitness criteria requiring meaningful worker representation in the governance, implementation, and oversight of initiatives.

    The Guidelines should therefore establish clear fitness criteria requiring meaningful worker representation in governance, implementation and oversight.

  • The Guidelines should explicitly recognise binding instruments such as Collective Bargaining Agreements and Global Framework Agreements as best practices.

    The Guidelines should explicitly recognise these established mechanisms as examples of good practice.

• NSZZ "Solidarność" Trade union, POL model reads as: wants changes source
  • The Commission should evaluate human rights due diligence by its impact on rightsholders rather than primarily by compliance cost reduction.

    effective human rights due diligence should be evaluated by its ability to identify, prevent and remedy adverse risks to and adverse impacts on rightsholders-not simply by minimising compliance costs.

  • The Guidance should recognise freedom of association and collective bargaining as severe and highly likely risks across sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • The Guidelines must establish practical expectations ensuring timely input, sufficient information, resources, and protection from retaliation for worker representatives.

    Accordingly, timely opportunities for input before decisions have been made, advance access to sufficient information to engage meaningfully, protected time and resources for engagement, and safe channels for communicating sensitive findings without exposure to retaliation are essential.

• Micro company, NLD NGO, NLD model reads as: wants changes source
  • The Commission should evaluate effective human rights due diligence by rightsholder outcomes rather than focusing on minimising administrative compliance costs.

    effective human rights due diligence should be evaluated by its ability to identify, prevent and remedy adverse risks to and adverse impacts on rightsholders- not simply by minimising compliance costs.

  • The Commission should recognise freedom of association and collective bargaining as severe and highly likely risks across sectors in the Guidance.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • Governments should establish a committee composed of labor union leaders and experts to oversee supervisory bodies and advise on CSDDD implementation and enforcement.

    To adequately fulfill the requirement governments should establish a committee for labor union leaders and experts to oversee new supervisory bodies and advise on implementation and enforcement of CSDDD.

• International Trade Union Confederation NGO, BEL; register: Trade unions and professional associations model reads as: wants changes source
  • Due diligence should be evaluated by its ability to identify and remedy adverse impacts rather than by administrative costs alone.

    Effective due diligence should be judged by outcomes, not administrative cost alone

  • The guidelines must highlight freedom of association and collective bargaining as enabling rights that underpin all other labour rights.

    The Guidelines must highlight the role of freedom of association and collective bargaining as enabling rights that underpin the effective protection of all other labour rights.

  • The Commission should recognise freedom of association and collective bargaining as severe and highly likely risks across sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

• Micro company, ESP Business association, ESP model reads as: wants changes source
  • The guidelines should avoid prescribing a common set of indicators or treating specific indicators as mandatory compliance benchmarks.

    The Guidelines should therefore not prescribe a common set of indicators or treat particular indicators as mandatory compliance benchmarks.

  • Companies should retain flexibility to adapt indicators without the use or non-use of any indicator determining compliance.

    Companies should retain flexibility to select, develop and adapt indicators to their circumstances; and the use or non-use of a particular indicator should not itself determine compliance.

  • The guidelines should not require complete certainty or rigid scoring methodologies.

    The Guidelines should not require complete certainty or rigid scoring methodologies.

• CFDT Trade union, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Place meaningful stakeholder engagement and social dialogue at the centre of due diligence implementation.

    place meaningful stakeholder engagement and social dialogue at the centre of due diligence

  • Recognize freedom of association and collective bargaining as severe and highly likely risks that must be assessed across all sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance

  • Ensure meaningful involvement of worker and trade union representatives in all stages of due diligence processes.

    stipulate that meaningful involvement of worker and trade union representatives is essential to all steps of due diligence on these rights

• COMISIONES OBRERAS Trade union, ESP; register: Trade unions and professional associations model reads as: wants changes source
  • The guidance should evaluate due diligence primarily by its concrete impact on rightsholders rather than focusing purely on administrative cost reductions.

    While appropriateness and proportionality are important, effective human rights due diligence should be evaluated by its ability to identify, prevent and remedy adverse risks to and adverse impacts on rightsholders-not simply by minimising compliance costs.

  • The Commission should designate freedom of association and collective bargaining as severe, highly likely risks across all sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • The guidelines must stipulate that substantive trade union and worker representative participation is required across all due diligence stages.

    stipulate that meaningful involvement of worker and trade union representatives is essential to all steps of due diligence on these rights.

• Germanwatch e.V. NGO, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • All multi-stakeholder initiatives should be based on the UN Guiding Principles and OECD Guidelines.

    All MSIs should be based on the internationally recognised UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises.

  • Objectives within multi-stakeholder initiatives should be binding at the individual company level and include deadlines.

    Objectives should be binding at the individual company-level and include deadlines.

  • Multi-stakeholder initiatives should provide a grievance mechanism open to all members and external stakeholders.

    MSIs should provide a grievance mechanism open to all members, in case of a violation of the agreed objectives by a member.

• Lithuanian Trade Union Confederation Trade union, LTU; register: Trade unions and professional associations model reads as: wants changes source
  • Effective due diligence should be evaluated by outcomes for rightsholders rather than compliance costs alone.

    Effective due diligence should be judged by outcomes, not administrative cost alone

  • The guidelines must highlight freedom of association and collective bargaining as enabling rights.

    The Guidelines must highlight the role of freedom of association and collective bargaining as enabling rights that underpin the effective protection of all other labour rights.

  • Companies should be required to assess freedom of association and collective bargaining rights across their operations and value chains.

    require companies to assess these rights throughout their operations and value chains;

• Micro company, ESP Company, ESP model reads as: wants changes source
  • Guidance should specify that digital solutions must retain the underlying data, source, date, and method version for each decision.

    We therefore recommend that the guidelines state that a digital solution relied upon under Article 8(3) should, at a minimum, retain for each such decision: the information on which it was based, the source of that information, the date, and the version of the method or criteria applied.

  • The necessity and subsidiarity tests under Article 8(2a) need an operational form to prevent them from being satisfied automatically on paper.

    The necessity and “no other reasonable means” tests of Article 8(2a) need an operational form, or every request will satisfy them on paper.

  • Assurance metadata should accompany shared information using the definition in Article 3(1)(h).

    Assurance metadata should travel with the information, using the definition already in Article 3(1)(h).

• ActionAid International NGO, NLD; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The scope of the directive should cover all types of business relationships across the entire value chain.

    That is why the CSDDD should include all types of business relationships throughout the value chain.

  • Companies of all sizes should be included in the scope of the directive so that women workers can benefit.

    Women will not benefit from this legislation, unless companies of all sizes are included in the CSDDD.

• SolarPower Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should provide illustrative, practical, and sector-specific examples of adverse impacts that do not expand the Directive's scope.

    The Guidelines should provide practical, sector-specific examples of adverse human rights and environmental impacts to improve consistency, risk identification and due diligence.

  • The Commission should establish an EU-level risk database to centralise data and facilitate risk prioritisation.

    An EU-level database would improve consistency, reduce duplication of effort and provide a common baseline through verified risk data, access to recognised industry schemes and MSIs, and high-risk region mapping.

• Micro company, NLD NGO, NLD model reads as: wants changes source
  • Legislation and guidelines must include a definition of vulnerable or marginalised stakeholders taking intersectionality into account.

    Een definitie van ‘kwetsbare of gemarginaliseerde stakeholders’, die mogelijk een verhoogd risico lopen op veronachtzaming van hun belangen; en met oog voor hoe diverse factoren van marginalisatie5 samenhangen en op elkaar inwerken (intersectionaliteit).

  • Due diligence must include an explicit obligation to pay special attention to the rights, needs, and challenges of vulnerable or marginalised stakeholders.

    Een expliciete verplichting dat het uitvoeren van due diligence moet plaatsvinden met bijzondere aandacht voor de rechten, behoeften en uitdagingen van deze ‘kwetsbare of gemarginaliseerde stakeholders’.

  • Companies must be explicitly required to implement meaningful stakeholder engagement across all stages of the due diligence process.

    Een expliciete verplichting om betekenisvolle stakeholderengagement te implementeren in alle stappen van het due diligence proces, met speciale aandacht voor de barrières voor participatie van kwetsbare of gemarginaliseerde stakeholders, gendersensitiviteit en mensenrechtenverdedigers6.

• FoodDrinkEurope Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should provide guidance documents by 26 July 2027 to allow companies sufficient time to prepare.

    We expect guidance documents to be made available at the latest by 26th of July 2027, thus allowing companies adequate time to integrate best practices into their internal processes.

  • The guidance should operationalise measures to prevent trickle-down effects on out-of-scope companies.

    The guidance should explicitly operationalise the Omnibus I provisions aimed at limiting the trickle-down effect on out-of-scope companies, including the obligation for in-scope companies to rely on risk-based prioritisation and reasonably available information, rather than systematic data collection across entire supply chains.

  • The Commission should establish a uniform definition, methodology, and country benchmarking for living income and living wage.

    A uniform, binding definition and methodology for determining living income / living wage should be provided.

• Italian Coalition Campagna Impresa 2030 Diamoci una Regolata! Other, ITA model reads as: wants changes source
  • The Guidelines should clarify that climate-related impacts fall under the CSDDD definitions of adverse human rights and environmental impacts.

    The Guidelines must clarify that climate-related impacts fall under the CSDDD’s definitions of adverse human rights and environmental impacts (in particular under Point 15 of the Annex).

  • The Guidelines should include a non-exhaustive list of examples of adverse impacts, especially those linked to climate.

    The Guidelines should include a non-exhaustive list of examples of adverse human rights and environmental impacts, particularly those that are climate-related and covered in Point 15 of the Annex.

  • The Guidelines should explain specific legal tests and clarify additional standards under Recital 33.

    The Guidelines should also explain the test in Art 3(1)(c)(ii), provide examples of "legal interest", "direct impairment", and “foreseeability” & clarify “additional standards” under Recital 33, including for high-risk contexts, FPIC & gender.

• Micro company, ITA Other, ITA model reads as: wants changes source
  • The Guidelines should define the role of third-party verifiers by clarifying the nature and subject matter of their engagement.

    Assirevi considers that the primary purpose of the Guidelines should therefore be to define the role of third-party verifiers by clarifying the subject matter of the engagement and its nature.

  • Third-party verification should focus on the design and implementation of the company's due diligence system rather than direct verification of substantive compliance.

    Accordingly, it appears consistent with the objectives of the Directive for third-party verification to focus on the design and implementation of the due diligence system established by the company to comply with the requirements of the Directive (including its governance arrangements, policies, processes, procedures, controls and monitoring activities), rather than on the direct verification of compliance with every substantive obligation, including the identification, assessment and prioritization of actual or potential adverse impacts, as well as their mitigation and remediation.

  • Verification should be framed as an attestation engagement applying IAASB international assurance standards.

    Framing the engagement in this way would allow third-party verification to be performed as an attestation engagement, applying internationally recognized assurance methodologies drawn from the international standards on assurance engagement issued by the IAASB.

• MEDEF Business association, FRA model reads as: wants changes source
  • The Guidelines must remain practical, illustrative, and non-binding without expanding the scope or obligations of the Directive.

    The Guidelines must remain practical, illustrative, and non-binding. Under no circumstances should they broaden the scope of the directive, whether through interpretations or overly detailed examples. Similarly, they must not impose additional obligations on companies.

  • Initial scoping under Article 8 should rely on reasonably available information without requiring exhaustive mapping or continuous monitoring.

    The two-stage logic of Article 8 must remain central. Initial scoping should use reasonably available information to identify where impacts are most severe and likely; targeted in-depth assessment should follow only where justified by that scoping or a credible concern. The Guidelines should imply neither exhaustive mapping, systematic assessment of every entity nor continuous monitoring, but to remain within the framework set forth by the directive.

  • The Guidelines should prioritize articulation with other EU sustainability regulations to avoid duplication and permit the reuse of existing assessments.

    The Guidelines should place a high priority on articulation withthe CSDDD interacts with the CSRD, EUDR, and the Forced Labour, Batteries and Conflict Minerals Regulations. They should clarify overlaps and lex specialist, permit reuse of existing assessments, and avoid duplicate requests or sanctions for the same conduct.

• The Central Organisation of Finnish Trade Unions SAK Trade union, FIN; register: Trade unions and professional associations model reads as: wants changes source
  • The Commission should recognize freedom of association and collective bargaining as severe and highly likely risks across sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • Companies should be required to assess freedom of association and collective bargaining throughout their operations and value chains.

    require companies to assess these rights throughout their operations and value chains;

  • Meaningful involvement of trade unions and worker representatives must be stipulated as essential across all due diligence steps.

    stipulate that meaningful involvement of worker and trade union representatives is essential to all steps of due diligence on these rights.

• EFFAT Trade union, BEL; register: Trade unions and professional associations model reads as: wants changes source
  • The Commission should recognize freedom of association and collective bargaining as severe and highly likely risks across sectors.

    recognise freedom of association and collective bargaining as severe and highly likely risks across sectors and highlight this in the Guidance;

  • Companies should be required to evaluate freedom of association and collective bargaining throughout their operations and supply chains.

    require companies to assess these rights throughout their operations and value chains;

  • The Guidelines must establish that meaningful worker and trade union participation is essential across all due diligence stages.

    stipulate that meaningful involvement of worker and trade union representatives is essential to all steps of due diligence on these rights.

• Glencore Company, BEL model reads as: wants changes source
  • Postpone the entry into force of the Directive until clear guidance is provided and the review under the Omnibus Simplification Package concludes.

    The entry into force of the Directive should be postponed at least until co-legislators will have provided clear, timely guidance on the implementation phase, and until the end of the ongoing review process under the announced Omnibus Simplification Package.

  • Include a reasonable best-efforts clause to limit liability for companies acting without knowledge or suspicion of infringements.

    Include a reasonable best-efforts clause to mitigate potential impacts resulting from a complex set of definitions and implementing requirements

  • Provide clear guidelines to clarify how companies should identify, assess, and report on adverse impacts in their chain of activities.

    Provide clear guidelines (Article 19) to clarify how companies are expected to identify, assess and report on actual and potential adverse impacts in the chain of activities and prioritise them based on severity and likelihood.

• BusinessEurope Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure the guidelines remain strictly non-binding and do not expand the scope or obligations of the Directive.

    be clearly non-binding and not expand the scope and obligations of the CS3D;

  • Ensure the guidelines are principle-based, simple, and avoid excessive prescriptiveness.

    be principle-based, simple and not overly prescriptive;

  • Consult stakeholders again once the draft guidelines are ready.

    It is essential that once the draft guidelines are ready, stakeholders are given the opportunity to be consulted on those to be able to, where appropriate, feed practical knowledge and solutions so the guidelines produce actual tangible results.

• ONCE Social Group Other, ESP; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Explicitly recognise international and European disability rights instruments as a key complementary interpretative framework for the Directive.

    the ONCE Social Group believes that the Guidelines should explicitly recognise these instruments as a key complementary interpretative framework for the implementation of the Directive.

  • Promote regulatory coherence between the CSDDD and the broader European sustainability framework, including CSRD and ESRS.

    The Guidelines should also promote coherence between the CSDDD and the broader European sustainability framework.

  • Expressly consider disability-related adverse impacts and associated risks in due diligence guidelines.

    The CSDDD Guidelines should therefore expressly consider disability-related adverse impacts, and the risks associated with failing to address such impacts, as part of the due diligence perspective.

• ACEA - The European Automobile Manufacturers' Association Business association, BEL model reads as: wants changes source
  • Avoid creating additional obligations or turning voluntary standards into binding requirements through the guidelines.

    Avoid creation of additional obligations

  • Fully recognize the risk-based approach and reinforce the principle that due diligence is an obligation of means.

    Recognize the risk-based approach fully

  • Provide guidance on addressing practical limits where compliance conflicts with third-country legal requirements.

    Take into account third-country legal limitations or requirements

• EuropeanIssuers Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Consult stakeholders again on the draft guidelines before final adoption.

    EuropeanIssuers encourages the European Commission to consult stakeholders again on the draft Guidelines before their final adoption, at least on the most critical topics, for instance, the identification of adverse impacts in the value chain, risk factors, prioritisation of adverse impacts, responsible purchasing practices and remediation.

  • Keep the guidelines principles-based, risk-based, and proportionate while avoiding prescriptive checklists.

    Remain principles-based, risk-based and proportionate

  • Recognize that due diligence obligations are duties of means and provide practical guidance on operating under legal constraints.

    Recognise that due diligence obligations are duties of means

• U.S. Mission to the EU Public authority, USA model reads as: opposes source
  • Significantly limit CSDDD and CSRD reporting and due diligence requirements on U.S. businesses and limit enforcement actions against them.

    Significantly limit CSDDD and CSRD reporting and due diligence requirements on U.S. businesses, and limit enforcement actions against U.S. businesses.

  • Prohibit levying penalties on U.S. businesses or their EU subsidiaries based on non-EU revenue.

    Prohibit the levying of any penalty on a U.S. business, or an EU subsidiary of a U.S. business, that is based on revenue derived from activities outside the EU.

  • Eliminate Article 2.2(a)-(c) to restrict the scope of CSDDD exclusively to EU-domiciled businesses.

    Therefore, we request that the EU eliminate CSDDD Article 2.2(a) -(c), narrowing the scope to EU-domiciled businesses.

• European Coffee Federation Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Anchor due diligence in risk-based prioritisation rather than exhaustive data collection across supply chains.

    Anchor due diligence in risk-based prioritisation, not exhaustive data collection

  • Reflect the structural realities of smallholder-dominated supply chains in the guidelines.

    Reflect the structural realities of smallholder-dominated supply chains

  • Ensure coherence and interoperability across the EU sustainability acquis to avoid duplicate requirements.

    Ensure coherence and interoperability across the EU sustainability acquis

• Cefic, the European Chemical Industry Council Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The guidance must not expand the scope of obligations, introduce additional requirements, or diminish company compliance flexibility.

    it is important that it does not have the effect of expanding the scope of companies’ obligations, introducing additional requirements, or reducing the flexibility afforded to companies under the Directive in determining appropriate compliance approaches.

  • Guidance should clarify that existing corporate policies and systems can satisfy the requirement for a due diligence policy.

    Guidance should therefore clarify that the requirement for a due diligence policy under CS3D Article 7(1) and (2) can be met by existing corporate policies and systems, where these are substantially equivalent and encompass the priorities established by the Directive.

  • The Commission should avoid expanding the list of international conventions and treaties included in the Annex.

    The Commission should not expand the list of conventions and treaties included in the Annex.

• Temasek Company, SGP; register: Companies & groups model reads as: wants changes source
  • The Commission should tailor guidance to the non-operational nature of financial holding entities by limiting obligations relative to independent subsidiaries.

    Alternatively, the CSDDD implementation guidelines to be published by the Commission should include language that has regard to the practical and/or legal limitations of FHUs in defining their obligations and liabilities arising from the operations of their subsidiary undertakings.

  • Risk scoping and impact assessment for financial holding entities should be grounded strictly in reasonably available external information.

    For FHUs, risk scoping should be based on information that is reasonably available to the investor.

  • The Commission should issue EU-level guidance ensuring policy consistency with CSRD so that financial holding due diligence does not cover independently managed subsidiaries.

    A valuable role the European Commission can play is to issue clear EU-level guidance that ensures policy consistency between the CSRD and CSDDD as regards to the treatment of FHUs.

• Aerospace, Security and Defence Industries Association of Europe (ASD) Business association, BEL model reads as: wants changes source
  • Commission guidance should avoid being overly prescriptive and provide sufficient flexibility to accommodate complex multi-tier supply chains and national regimes.

    Commission guidance should avoid an overly prescriptive text and allow sufficient flexibility for companies to implement CSDDD requirements while providing clear guidance to the Member States towards a harmonised implementation of the text.

  • The Commission should provide guidance and safeguards for cases where third-country legislation limits supplier data disclosure.

    The Commission should provide practical guidance on situations where third-country legal frameworks restrict access to supplier information or prevent the transfer of due diligence-related data, such as: Chinese Decree 834 Regulations on the Security of Industrial and Supply Chains (March 2026) and Decree 835 Regulations on Countering Improper Extraterritorial Jurisdiction by Foreign States (April 2026).

  • The guidelines should clarify that sector-specific legal restrictions, confidentiality, and national security constraints prevent disclosure of certain sensitive information.

    In practice, some information may not be disclosed because of confidentiality, security sensitivity or legal restrictions, and guidance should consider and clarify this.

• The Ethical Trading Initiative Other, GBR model reads as: wants changes source
  • The guidelines should clarify expectations when supply chain visibility remains limited despite reasonable efforts and require due diligence to be embedded across daily operational documents.

    The guidelines should also address what is expected of companies where supply chain visibility remains limited despite reasonable efforts.

  • The guidelines should anchor treatment of living wage and living income benchmarks in the ILO's 2024 tripartite agreement.

    The ILO's 2024 tripartite agreement on living wages reflects international consensus on the principles and methodologies for wage-setting and estimating living wages and should anchor the guidelines' treatment of living wage and living income data.

  • Apportionment of remediation responsibility must never reduce remedy to affected people, requiring remaining responsible companies to cover any shortfalls.

    As stated in our questionnaire response, apportionment must never reduce the remedy: the entitlement of affected people should be established first, in full; the buyers involved should then apply a single apportionment methodology commonly agreed for that case; and where a contributor cannot or will not meet its share, the remaining responsible companies should cover the shortfall rather than leave affected people partially remediated.

• FuelsEurope Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Guidelines should explicitly clarify that recommendations and examples are non-prescriptive and do not create autonomous compliance standards or de facto binding expectations.

    In particular, it should be explicitly stated that any recommendations, indications, or examples contained in the Guidelines are neither prescriptive nor exhaustive, and thus should not become de facto binding expectations for companies or supervisory authorities.

  • The Guidelines must strictly respect the scope defined in the CSDDD Annex and avoid introducing additional concepts or adverse impacts.

    Any Guidelines should refrain from introducing additional concepts or addressing adverse impacts that are not covered by the Directive.

  • The Guidelines should recognize the legitimacy of relying on reasonably available public and external information sources rather than requiring exhaustive visibility across complex value chains.

    The Guidelines should therefore recognise the legitimacy of using public sources, sectoral resources, ESG datasets, country-risk indices, industry schemes, stakeholder input and internal risk registers, or any other appropriate sources, based on the essential concept of “reasonably available information”.

• Norsk Hydro Company, NOR; register: Companies & groups model reads as: wants changes source
  • The Guidelines should focus on illustrating acceptable practice and practical adequacy rather than exclusively describing best practice.

    providing practical examples of adequate ("good enough") due diligence rather than only describing best practice;

  • The Guidelines should establish clear thresholds for when due diligence obligations are fulfilled even if adverse impacts cannot be completely eliminated.

    clearly defining when companies can reasonably be considered to have fulfilled their due diligence obligations, even where adverse impacts cannot be fully prevented or eliminated.

  • Supervisory authorities should focus on learning and consistency rather than early liability-driven enforcement.

    Supervisory efforts should initially prioritize consistency, learning and continuous improvement over a strongly liability-focused approach.

• Mondelēz International Company, USA; register: Companies & groups model reads as: wants changes source
  • The guidelines should establish principles and a flexible decision-making framework rather than a closed checklist of mandatory actions.

    Set out principles, not a checklist. Give companies a framework to decide, backed by examples, not a fixed list of required actions.

  • The Commission should clearly separate expectations and methodologies for broad initial scoping from in-depth risk assessments.

    The single most useful thing the guidelines can do is separate two different jobs: the broad initial scoping of where risks may lie, and the in-depth assessment of the most severe and likely risks, required under Article 8.

  • The guidelines should ensure coherence across EU due diligence regulations to eliminate duplicated reporting under a report once, use many times approach.

    Make the EU's due diligence rules work together. Let the work and data done for the CSRD, EUDR and Forced Labour Regulation count for the CSDDD: report once, use many times.

• Hauptverband der Deutschen Bauindustrie e.V. Business association, DEU; register: Trade unions and professional associations model reads as: wants changes source
  • The guidelines should introduce de minimis monetary thresholds below which risk assessment is treated as secondary.

    Recommendation 1: The CSDDD Guidelines should mention de minimis thresholds below which risk assessment is of secondary importance. HDB would suggest 50.000 Euro per subcontractor and 10000 Euro for all other suppliers.

  • The Commission should provide standardised sector-level risk factors assigned to individual NACE codes.

    Recommendation 2: The Guidelines should include the EU Commission’s assessment of the risks associated with individual economic sectors with regard to their abstract risk (i.e. not pertaining to an individual company, but rather a risk environment in which these might operate). Specifically, a risk factor should be assigned to each NACE code by the EU Commission, with a view to achieving standardisation.

  • The Commission should publish abstract country risk factors to enable standardised country-of-origin risk analysis.

    Recommendation 3: The Guidelines should include the EU Commission’s assessment of the risks in each individual country in the form of an abstract risk factor, which can be used for an abstract risk analysis and enables standardisation

• ANSA (Association nationale des sociétés par actions) Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • The guidelines must not establish any new requirements or liabilities beyond the directive's existing scope.

    This means that no new requirements should be added to the obligations arising from the text, whether for corporates within the scope of the due diligence duty or for SMEs, whether direct or indirect partners in the value chain. Consequently, no additional liability should be established in the event of non-compliance with these guidelines.

  • The Commission should submit the first draft of the guidelines for consultation to allow companies to provide feedback.

    Given the time allowed for transposition and initial application, we would also stress that the first draft of the guidelines should again be submitted for consultation, so that companies can share their initial comments.

  • The guidelines should avoid expanding the scope beyond the Directive's Annex and prevent indirect climate-related obligations.

    The guidelines should strike a balance between clarity and flexibility, and should avoid expanding the scope beyond the Directive's Annex - including through any indirect reintroduction of climate-related obligations.

• EIC - European International Contractors Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Negotiators should significantly raise employee and worldwide net turnover thresholds for in-scope companies.

    EIC welcomes that Council and Parliament agree on the need to increase significantly the thresholds relating to net worldwide turnover and the number of employees, bearing in mind that the current thresholds put a disproportionately heavy administrative burden on medium- sized companies active in the construction industry and beyond.

  • In-depth due diligence assessments should be restricted to tier 1 business partners.

    For the sake of legal clarity, we support the position of the Commission and the Council to limit the requirement to conduct in-depth assessments to ‘tier 1’ business partners rather than retaining the concept of a two-step analysis for the entire supply chain.

  • Mandatory climate transition plans should be deleted from the directive.

    EIC strongly endorses the proposal of the Parliament to delete all references to the mandatory adoption of a climate transition plan given the existence of similar regulation in other areas of the EU ‘acquis communautaire’, on the one hand, and bearing in mind the risk of antagonising non-EU in-scope companies and their governments, on the other hand.

• German Association of the Automotive Industry (VDA) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • The guidelines must provide illustrative and non-binding advice without introducing new or further-reaching obligations.

    It is essential that practical, illustrative and non-binding guidance is provided, without creating new or further- reaching obligations for companies.

  • The guidelines should uphold the principle that due diligence is an obligation of means.

    Guidelines should at all times underpin the obligation of means as the main principle on which the CSDDD is based.

  • The guidelines should offer guidance on navigating mandatory third-country legal conflicts.

    The Guidelines should provide support for companies on how to deal with complex situa- tions like these. Companies cannot be expected to expose themselves, associated companies, subsidiaries, business partners, individuals or employees to legal, regu- latory or personal risks.

• Eurogroup for Animals NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Animal welfare should be explicitly recognised in the forthcoming Guidelines as a material risk and impact factor for corporate due diligence.

    To this end, animal welfare should be explicitly recognised in the forthcoming Guidelines as one such material risk and impact factor for which companies and financial institutions should be provided with specific practical guidance.

  • The Guidelines should treat animal welfare as an indicator of broader environmental and human rights risks rather than creating an independent impact category.

    The Guidelines should therefore recognise animal welfare as an important indicator of broader sustainability risks rather than as a separate category of adverse impact.

• Deutsches Aktieninstitut e.V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • The Commission should ensure regulatory consistency and interoperability between CSDDD and CSRD/ESRS reporting frameworks.

    We therefore ask the Commission to ensure that the Guidelines explain how companies can bridge this gap.

  • The Guidelines should define and clarify the operational scope of reasonably available information.

    We ask the Commission to further specify the concept of reasonably available information in order to provide legal certainty and to ensure a proportionate, risk-based due diligence approach.

  • The Guidelines should recognise sector and business model diversity by avoiding rigid, standardised approaches.

    The Guidelines should avoid prescribing fixed policy lists, rigid methodological hierarchies or standardised indicator sets.

• Federal Association of Corporate Lawyers in Germany (BUJ) Business association, DEU; register: Trade unions and professional associations model reads as: wants changes source
  • The guidelines should adopt a principle-based approach tailored to individual risk profiles rather than imposing rigid, one-size-fits-all mandates.

    The guidelines should be based on general principles rather than on detailed policies and prescriptive requirements for the integration of due diligence into corporate poli- cies.

  • The guidelines must establish sequencing rules and safe harbours to resolve conflicts with the Forced Labour Regulation.

    The CS3D guidelines must provide a sequencing rule and safe har- bour for companies caught between these conflicting obligations.

  • The guidelines should promote legal certainty by providing safe-harbour rules for situations where compliance is legally or practically impossible.

    Safe-harbour rules should be offered in cases that confront companies with the legal or practical impossi- bility to comply with their due diligence obligations.

• ver.di Trade union, DEU; register: Trade unions and professional associations model reads as: wants changes source
  • The Commission should recognise freedom of association and collective bargaining as severe, highly likely risks across sectors and mandate the involvement of trade unions in related due diligence processes.

    We therefore call on the Commission to recognise these rights as severe and highly likely risks across sectors, require their assessment throughout operations and value chains, ensure they are systematically considered whenever other labour rights issues are identified, and mandate the meaningful involvement of workers and trade union representatives in all due diligence processes related to these rights.

  • The Guidelines should mandate meaningful worker and trade union representation in the governance, implementation, and oversight of initiatives or audit mechanisms.

    The Guidelines should therefore require meaningful worker and trade union representation in the governance, implementation and oversight of such mechanisms.

  • The Guidelines should avoid a narrow focus on short-term cost reduction and recognise effective due diligence as a long-term investment.

    The Guidelines should therefore avoid an overly narrow focus on short-term cost reduction and instead recognise effective due diligence as a long-term investment that benefits both rightsholders and businesses.

• U.S. Chamber of Commerce Business association, USA model reads as: wants changes source
  • Clarify that CS3D due diligence is a risk-management process rather than an outcome-based obligation.

    The guidelines should clearly affirm that due diligence under CS3D is a risk - management process and not an outcome -based obligation.

  • Establish that companies may prioritize due diligence where impacts are most acute rather than mapping every supply chain tier absent credible evidence of severe impact.

    A company may prioritize due diligence where adverse impacts are most likely and most acute and is not required to map every tier of every supply chain absent credible evidence of severe adverse impact .

  • Confirm that good-faith compliance with foreign legal restrictions and the use of reasonable alternatives should not lead to penalties.

    The guidelines should thereby confirm that where foreign privacy, secrecy, national security, commercial confidentiality, or similar legal restrictions prevent collection, transfer, audit, receipt, or disclosure of information, documented compliance with those local restrictions and use of reasonable alternatives should constitute good -faith best efforts and should not give rise to penalties.

• The Circle NGO NGO, GBR; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Implement the CSDDD in a gender-responsive manner with explicit guidance on gender-specific risk assessment, stakeholder engagement, and remedies.

    Implement the CSDDD in a gender-responsive way, using Commission guidance to require gender-specific risk assessment, stakeholder engagement and remedies.

  • Ensure that due diligence requirements cover full global value chains including subcontracting and informal work.

    Ensure adequate due diligence is understood to cover full global value chains, including subcontracting, labour intermediaries and informal work.

  • Include living wages and purchasing practices as core risk factors within due diligence obligations.

    Address living wages and purchasing practices as core risk factors within due diligence obligations.

• SMEunited Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The guidelines must provide practical safeguards to prevent disproportionate burdens from trickling down onto SMEs.

    The guidelines must provide practical safeguards to ensure SMEs are not subject to a trickle-down effect leading to disproportionate burdens arising from the due diligence obligations of larger companies.

  • The guidelines should ensure information requests directed to SMEs are proportionate and risk-based.

    Ensure that information requests to SMEs are proportionate and risk-based

  • The guidelines must follow the Think Small First principle and address the challenges of the smallest enterprises.

    Therefore, SMEunited demands that the guidelines, legally required under article 20 of CS3D, follow the Think Small First principle, addressing the challenges of the smallest companies in supply chains.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • The CSDDD guidelines should promote consistency and facilitate the reuse of information and processes across EU legislation, especially the Forced Labour Regulation.

    The CSDDD guidelines should promote consistency and make it easier to reuse relevant information and assessment processes across the CSDDD, CSRD/ESRS, the EUDR and the FLR.

  • More practical guidance is needed regarding the later stages of due diligence, including stopping, preventing, and mitigating adverse impacts as well as handling remedy and grievances.

    More practical guidance is needed on what comes next, including actions to cease, prevent and mitigate adverse impacts, the handling of grievances, remedy and the measurement of impact.

  • The CSDDD guidelines must clarify the respective roles and allocation of group-wide responsibilities between parent companies and subsidiaries.

    The CSDDD guidelines should clarify the respective roles of parent companies and subsidiaries, and how group-wide requirements, Ref. Ares(2026)7900552 - 14/08/2026 2 responsibilities, oversight and accountability can be organised when subsidiaries operate in different legal and commercial contexts.

• World Wide Fund For Nature (WWF) NGO, CHE; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The Commission should adopt a prescriptive, step-by-step approach in the guidance rather than relying solely on high-level principles.

    It is crucial to provide clear, actionable steps instead of relying only on a principle-based approach, which is already found in the Level 1 legislation.

  • The guidance should provide simplified, user-friendly communication formats layered for non-experts.

    Wherever possible, it is important to create a layered guidance designed for non-experts, including an easily navigable format with an introduction, navigation table, and streamlined action items.

  • The guidance should build upon and align with existing international due diligence frameworks.

    Ensuring that the guidance is built upon established frameworks and relevant documents, and draws explicit connections to existing framework materials, will help stakeholders understand how they inform the CSDDD.

• ClientEarth NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The guidelines should include practical, sector-specific examples of adverse environmental impacts within the scope of the CSDDD.

    The Commission guidelines should therefore provide practical, sector-specific examples of adverse environmental impacts falling within the scope of the CSDDD, while making clear that those examples are illustrative and non-exhaustive.

  • The guidelines should confirm that harmful emissions include climate change impacts from greenhouse gas emissions, including Scope 3.

    The guidelines should also expressly confirm that “harmful emissions” within the meaning of Point 15 include climate change impacts arising from anthropogenic greenhouse gas (GHG) emissions, including relevant Scope 3 emissions.

  • The guidelines should clarify that environmental due diligence does not solely depend on immediate human rights impacts.

    The guidelines should clarify that environmental due diligence should not only depend on the existence of an immediate or clearly identifiable human rights impact.

• Milieudefensie (Friends of the Earth Netherlands) NGO, NLD; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • The Guidelines must clarify that climate-related risks and impacts have to be considered throughout all steps of due diligence.

    Therefore, it is key that the Guidelines clarify that climate-related risks and impacts must be taken into account in all steps of due diligence.

  • Decision-making for the guidelines should be grounded in broad consultation and impact assessment without disproportionate corporate access.

    In developing the guidelines to support the implementation of the CSDDD, we request the Commission to base your (future) decision making on broad consultation, a proper impact assessment, without disproportionate access for major polluters.

• EU Sustainable Supply Chains Coalition Other, GBR; register: Other organisations, public or mixed entities model reads as: wants changes source
  • The guidelines should clarify that companies can rely on reasonably available information and credible third-party sources without exhaustive supplier-by-supplier mapping during identification.

    The guidelines should clarify that companies may rely on reasonably available information, including existing internal information and credible third-party, sectoral and country-level sources, without requiring exhaustive supplier-by-supplier data collection during the identification stage.

  • Guidance should clarify that companies must evaluate their own purchasing practices as part of adverse impact assessments.

    The guidance should also clarify that companies’ own purchasing practices form part of the assessment of actual and potential adverse impacts.

• ExxonMobil Petroleum & Chemicals BV Company, BEL; register: Companies & groups model reads as: wants changes source
  • Guidelines should allow companies to reasonably rely on compliance with effective local regulatory systems as an indicator of lower risk.

    The guidelines should clarify that, where these local systems are comprehensive and effectively enforced, compliance with their requirements represents meaningful, real-world action on the kinds of harm with which CSDDD is concerned.

  • Companies should be allowed to take into account business partner assessments from due diligence requirements or credible initiatives.

    By the same logic, where a business partner is subject to due diligence requirements or participates in credible industry or multi-stakeholder initiatives, companies should be able to take those assessments into account unless there are obvious deficiencies or other credible indications of elevated risk.

  • Guidance should confirm that established international rules on jurisdiction and applicable law are not displaced.

    Guidance should confirm that these established rules governing which country’s laws apply and which courts have authority are not displaced by implementation measures.

• Council of Bars and Law Societies of Europe (CCBE) NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Exclude legal services provided by lawyers from the scope of the Directive.

    In view of these principles inherent to the practice of the legal profession, we would therefore like to ask you to include a specific point in the Directive to make it clear that legal services provided by lawyers are not covered by the Directive.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • The guidelines should confirm that prioritisation does not require working through every operation in sequence and should protect good-faith prioritisation choices from liability.

    The guidelines should say this in plain terms, and should resist replacing that judgement with a single prescribed prioritisation model, given how differently companies are structured. They should also confirm that prioritisation does not oblige a company to work through every part of its operations in sequence, and that a company able to show a documented, reasonable, good-faith basis for its choices should not be exposed to liability merely because a regulator, or anyone else, would have drawn the line in a different place.

  • The guidelines should establish a structured framework for supervisory authorities to accommodate conflicts between CSDDD expectations and local laws.

    The guidelines should acknowledge that this happens, confirm that companies should not be forced to choose between one legal obligation and another, and give supervisory authorities a clear, structured basis for taking a genuine conflict of laws into account, looking at how clear the local restriction actually is, what the company did to establish and record it, whether it sought clarification or an exemption where one was realistically available, how much influence it actually had over the situation, and whether it kept the position under review rather than treating it as settled once and for all.

  • The guidelines should clarify that civil courts should give weight to supervisory authority findings to prevent divergent civil litigation.

    The guidelines should make clear that civil courts ought to give real weight to a competent supervisory authority's findings where the two overlap, and that the Directive's purpose is to build reliable, consistent regulatory oversight, not to open a new and unpredictable channel for large-scale civil litigation.

• Micro company, DEU NGO, DEU model reads as: wants changes source
  • National and EU legislators must adhere to the prohibition of regression and principles of proportionality when implementing or amending due diligence laws.

    The prohibition of regression and the principle of proportionality set limits on the weakening of the LkSG. These arise from international and European law.

  • Member States must maintain and ensure effective civil claims for damages in national legislation pursuant to Article 29 CSDDD.

    Article 29 CSDDD continues to require Member States to ensure effective claims for damages in national law.

  • Companies must be required to evaluate risks beyond their direct suppliers using a risk-based scoping approach.

    The risk-based approach to the scoping exercise at the beginning of the risk analysis requires companies to address risks beyond their immediate suppliers.

124 more analysed submissions on the consultation page.