Corporate Sustainability Due Diligence Directive (CSDDD) EU Grain and Oilseeds Sector React to European Parliament Vote

COCERAL, FEDIOL, and FEFAC, representing the EU grain and oilseed trade, the industry
crushing oilseeds, refining vegetable oils and the animal feed industry, approve the
European Parliament’s push for stronger alignment of the CSDDD with the principles and
language of UN and OECD due diligence guidelines. However, other elements may be
detrimental to trade and supply chains without added value to addressing harmful human
rights and environmental impacts.
The strengthened risk-based approach and introduction of prioritisation of adverse impacts
based on their severity and likelihood is crucial to ensure that companies’ efforts are
targeted where they are most needed and can deliver the most impact. The risk-based
approach is also more in alignment with the existing international frameworks on due
diligence guidelines, which are built on best practices.
The provisions on civil liability offer greater legal certainty to companies and legal fairness
by limiting it to situations in which a company has “caused” or “contributed to a harm”.
We equally endorse the European Parliament’s inclusion of the obligation to develop sectorspecific guidelines for agriculture, group-level due diligence, ensuring harmonisation at EU
level, and the introduction of minimum standards for independent third-party verification
via a delegated act.
However, we regret the inclusion of suspension of products from free circulation or export
among the sanctions to be imposed by Member States, as this disruption to trade and
supply chains will not contribute to improvements in due diligence.
We now call on the European Parliament and Council to work towards a final text that is
truly consistent with a risk-based approach, in line with UN/OECD best practice; enhances
harmonisation to ensure a level playing field and avoid further internal market
fragmentation; and bases civil liability provisions on legal traditions around breachdamage-causality. We stand ready to contribute to the dialogue during the trilogue