Corporate Sustainability Due Diligence Directive (CSDDD) EU Grain and Oilseeds Sector Welcome Stronger Alignment with UN/OECD Principles in JURI Vote

COCERAL, FEDIOL, and FEFAC, representing the EU grain and oilseed trade, the industry
crushing oilseeds, refining vegetable oils and the animal feed industry, support the JURI
committee’s effort to improve consistency 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.

A welcome improvement to the Commission’s text is the clarification that obligations are
proportionate to the responsibility of a company in relation to a harm with the introduction
of a distinction between harm “caused”, “contributed to”, or “directly linked to”.
The strengthened risk-based approach and introduction of prioritisation of adverse impacts
based on their severity and likelihood, if maintained, will 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”.
Other positive aspects include the obligation to develop sector-specific guidelines for
agriculture, group-level due diligence, ensuring harmonisation at EU level as well as a level
playing field for all companies in scope, 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.

Overall, the JURI committee has made positive changes to the Commission’s Proposal. We
now call on the European Parliament in its plenary vote and on the Council during the
trilogue negotiations to cover other important and needed adjustments to make the
Directive legally clear, fit for purpose, and effective in combatting adverse environmental
and human rights impacts of business operations.