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JBCE cosigned with Joint Business Statement of the business community on the EU due diligence proposal (CS3D)


On 17 January 2023, JBCE, together with the European business community, shared a joint statement on the EU due diligence proposal (CS3D) with EU stakeholders.

The joint statement is to call for realism, proportionality, and workability for this framework to truly enable and guide businesses in taking necessary steps towards more sustainable supply chains.

The highlighted key points are:

  • The most important element of CS3D should be full harmonisation;
  • Focusing on all aspects within the whole value chain is neither manageable nor realistic. Companies should be able to prioritise the most salient risks (Risk based approach);
  • Regulating directors’ duties is unnecessary to reach the objectives of the proposal and does not belong in a due diligence framework.;
  • The list of norms/conventions in the Annex of proposal is too far reaching and generates legal uncertainty;
  • Clear guidance needs to be adopted to help companies comply with and national authorities to enforce the legislation;
  • The legislation should acknowledge the possibility of organising due diligence at group level.

For more information, please contact:

Nagisa Kagawa

Policy Manager (CSR)

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