Position Paper on the Corporate Sustainability Due Diligence Directive Guidelines

On 20 October 2026, JBCE submitted its position paper on the the Corporate Sustainability Due Diligence Directive Guidelines.

JBCE submitted feedback to the public consultation on the CSDDD guidelines, conducted between June and August 2026. This position paper complements that submission and highlights the key points that should be considered as the European Commission develops the guidelines.

JBCE believes that the forthcoming European Commission guidelines will play an important role in helping companies conduct due diligence in accordance with the CSDDD.

Companies are required to comply not only with the CSDDD but also with various due diligence-related frameworks within and outside the EU. They also face practical challenges arising from complex global supply chains, including traceability limitations, conflicts with third-country laws and geopolitical barriers.

Against this background, JBCE calls for practical guidelines that do not create new de facto obligations or impose a one-size-fits-all approach. Instead, the guidelines should enable companies to build on their existing efforts and conduct due diligence in a reasonable, flexible and risk-based manner.

Key points

・Improve coherence between the CSDDD, other EU due diligence-related legislation and comparable third-country frameworks.

・Provide practical guidance for situations involving conflicts with third-country laws and geopolitical barriers.

・Encourage the use of credible existing industry and multi-stakeholder initiatives to support integrated and collaborative approaches to due diligence.

・Ensure flexible and proportionate implementation that reflects traceability limitations, different levels of maturity among global supply chain actors and companies’ reasonable due diligence efforts.

・Publish the guidelines in a timely manner to allow companies sufficient time to prepare, and provide stakeholders with a meaningful opportunity to comment before the guidelines are finalised.