The Supply Chain Law Initiative has compiled the voices of prominent people who have expressed criticism of the EU Commission’s plans to scrap important aspects of the EU Supply Chain Directive (CSDDD) before it has even come into force:

Dr. Bärbel Kofler, Parliamentary State Secretary at the Federal Ministry for Economic Cooperation and Development:

„Today, in Germany and Europe in particular, we must stand up for our values ​​and a long-term stable and sustainable economic environment. The EU must be a reliable trading partner for people all over the world.“

Archbishop Stephan Burger, Freiburg i.Br.:

„We will do everything in our power to prevent this important progress towards a globally responsible and social market economy from being watered down.“

Dr. Katharina Reuter, the Managing Director of the Federal Association for Sustainable Economy:

„Binding and uniform rules are necessary to ensure that companies’ responsibility does not end on the company premises or with direct suppliers. The EU supply chain regulation starts precisely here, and the economy has invested accordingly. The proposed reversal would be fatal for human rights and environmental protection.“

See: Breiter Widerstand gegen Verwässerung der EU-Lieferkettenrichtlinie

As feared, the European Commission has presented a comprehensive package of measures designed to significantly simplify sustainability reporting and investment conditions in the EU. The aim is to ease the burden on companies, reduce bureaucracy and at the same time promote sustainable investments. A key point of the reform concerns sustainability reporting: around 80% of companies would be exempted from the previous reporting obligations. Companies would have to provide less data and some reporting obligations would become voluntary. This should reduce costs and reduce bureaucratic effort.

The situation is similar with due diligence obligations: companies would no longer have to check their direct business partners annually, but only every five years. In addition, the exchange of information with SMEs will be reduced in order to reduce their administrative burden. At the same time, civil liability at EU level is to be abolished so that companies cannot be prosecuted multiple times for possible violations.

Siehe: Kommission vereinfacht Vorschriften für Nachhaltigkeitsberichterstattung und EU-Investitionen: mehr als 6 Mrd. EUR an Entlastung beim Verwaltungsaufwand angestrebt

The Supply Chain Law Initiative analyses what the planned “Omnibus” regulation could mean for the European Supply Chain Law CSDDD. Specifically, the Omnibus regulation – announced for February 26, 2025 – is intended to “simplify” three central sets of rules:

• the EU Supply Chain Directive (CSDDD),
• the Sustainability Reporting Directive (CSRD) and
• the Taxonomy Regulation.

Under the guise of reducing bureaucracy and simplifying the system, the CSDDD, which has been in force since July 2024 and must be implemented into national law by July 2026, is at risk of being significantly watered down. The background to this is an intensive lobbying campaign by German, French and Italian business associations that have been opposing comprehensive sustainability requirements for years. This effort is supported by the European People’s Party (EPP) and parts of the CDU/CSU. Critics fear that these lobbying efforts – possibly in cooperation with right-wing extremist groups in the European Parliament – could lead to a serious weakening of human rights, environmental and climate protection requirements.

The Omnibus Regulation is primarily intended to reduce redundant reporting requirements without changing the “correct content” of the existing laws – this is von der Leyen’s official justification. In practice, however, the changes aim to shift the scope of the CSDDD (e.g. from companies with 1,000 to those with 5,000 employees) and to limit due diligence obligations to direct suppliers. It must be warned that this would exclude essential risk areas such as environmental destruction in mining or child and forced labor in developing countries. In addition, fines and civil liability would be eliminated, which could deprive victims of human rights violations of access to compensation.

There is fierce resistance to the planned changes within the EU. Social Democratic and Green groups in the European Parliament as well as numerous NGOs and non-governmental organizations are calling for the CSDDD to be consistently retained. Even within the EU Commission, some commissioners, such as Justice Commissioner Michael McGrath, are criticizing the planned gutting of sustainability legislation. The further political debate, especially in the European Parliament, remains crucial for Europe’s future course on sustainability.

Please refer: Briefing „Rollback des European Green Deal? Omnibus-Verordnung droht EU-Lieferkettenrichtlinie auszuhöhlen“ (German) 

The Supply Chain Due Diligence Act (LkSG), which has been in force since the beginning of 2023 (or 2024 for companies with 1,000 or more employees), obliges large companies to analyze human rights risks in their supply chains and to take preventive measures. A representative survey of works councils shows the extent to which the law has changed practice in companies and how various company groups (management, economic committee, works council, employees) are dealing with the issue.

Important results of the study are:

• Impact and differences between sectors: Around 36% of works councils state that their company is affected by the LkSG. The level of impact increases with the size of the company. Differences between sectors are also evident: Companies in trade, transport, hospitality, construction and business-related services are more likely to be affected than companies in the manufacturing industry.
• Measures in supply chains: Around 43% of works councils report that measures have been implemented in the last two years to review or change supply chains in order to comply with human and employee rights and environmental standards. The most common measures relate to the analysis, monitoring and control of the supply chain, while profound structural changes are less common. It is noteworthy that not all changes were made directly in response to the LkSG.
• Involvement of internal groups: Management is most intensively involved in the issue, followed by economic committees, works councils and the workforce. In companies affected by the LkSG, the issue of working conditions and human rights at suppliers is generally more intensive.
• Information deficits: Two thirds of the works councils surveyed do not feel sufficiently informed about the topic, although the level of information is higher in larger companies. There is therefore a clear need for action, also with regard to training and information offers for the co-determination bodies.

Overall, the article shows that the LkSG and the associated public debate are having an impact, but that there are also gaps in implementation and information. In addition to adapting supply chains, measures are being taken primarily for analysis and monitoring. In order to ensure comprehensive implementation and the active involvement of all company stakeholders, further educational initiatives and sufficient resources for co-determination are necessary.

Please refer: Das Lieferkettengesetz in der Praxis: Einschätzungen durch Betriebsräte

The French government’s alleged push for comprehensive deregulation of EU corporate sustainability laws, including the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD), is facing strong opposition from NGOs and civil society. Critics argue that it prioritizes business interests over pressing climate and social concerns. France’s proposal to postpone the CSDDD indefinitely and potentially exclude 70% of covered companies raises concerns about the EU’s broader sustainability agenda. Meanwhile, business and human rights experts, civil society organizations and 10 national human rights institutions have warned that such deregulation could lead to legal uncertainty. In contrast, 400 French companies have called on EU politicians to respect existing ESG reporting deadlines.

Siehe: France: CSOs criticise French government’s call for “massive regulatory pause” on EU legislation, incl. CSRD and CSDDD

The Federal Association for Materials Management, Purchasing and Logistics (BME) is clearly in favor of maintaining the German Supply Chain Act (LkSG), as it shows progress in implementation in companies and offers planning security. A recent study by the association shows that large companies in particular are coping well with the requirements of the law, such as when conducting risk analyses. However, challenges still exist when it comes to controlling indirect suppliers. The law is seen as preparation for the EU Supply Chain Directive, which will come into force in 2027.

Companies such as Unilever, KiK and Hapag-Lloyd emphasize the importance of legal and planning stability – also with regard to the validity of the existing LkSG – as changes can cause high costs and competitive disadvantages. However, the high effort required for various sustainability reports, which ties up resources, is criticized. Companies such as s. Oliver and KiK are therefore calling for a standardization of reporting requirements.

Siehe: Wirtschaftsverband fordert Beibehaltung des Lieferkettengesetzes

We are very pleased that Dr. Maria Flachsbarth was elected as the new chairwoman of XertifiX e.V. by the XertifiX general meeting on December 3, 2024. Mrs. Flachsbarth worked for many years as a politician, including as Parliamentary State Secretary in the Federal Ministry for Economic Cooperation and Development (BMZ). She wants to bring this wealth of experience to her work with XertifiX: “I am delighted to now be able to work with committed colleagues on the board of XertifiX e.V. and in cooperation with XertifiX Sozialprojekte e.V. to work specifically for fair working conditions in the natural stone sector, for education instead of child labor, health care and adequate nutrition for the people working in the quarries. Our goal is to work specifically towards achieving SDG 8 “Decent work and economic growth” of the UN Agenda 2030.”

We are very much looking forward to working with Maria Flachsbarth!

At the same time, we would like to thank our previous chairwoman, Ms. Ingrid Sehrbrock, for her many years of commitment to XertifiX. After more than 11 years as chairwoman of XertifiX, Ms. Sehrbrock decided not to run again and to vacate her position. During her term of office, the XertifiX standard was significantly expanded and the area of ​​​​activity expanded from India to China and Vietnam. During this time, Ingrid Sehrbrock visited India twice and China once to get a first-hand impression of the work in quarries and factories. She has made a significant contribution to the success of XertifiX in recent years, for which we are very grateful. We are therefore pleased that she will continue to support XertifiX. At the suggestion of the new chairwoman, Ingrid Sehrbrock was elected by the XertifiX Board of Directors as the new chairwoman of the XertifiX Board of Trustees, succeeding the previous chairwoman of the Board of Trustees, Mr. Heribert Scharrenbroich.

Heribert Scharrenbroich is resigning from his position as Chairman of the Board of Trustees at his own request and, together with Ms. Flachsbarth, is supporting the election of Ingrid Sehrbrock as his successor. We would like to thank Heribert Scharrenbroich very much for the many years of valuable support and advice he has given XertifiX. With his broad knowledge of development cooperation and his experience in this field, he has made a particularly significant contribution to the success of XertifiX. We are very pleased that he will remain a member of the XertifiX Board of Trustees.

Today (24th May 2024) the EU Supply Chain Act (officially: Corporate Sustainability Due Diligence Directive, CSDDD) was finally passed by the Council of the EU. The EU states now have two years to implement the directive into national law.

The CSDDD gradually applies to companies of different sizes in the EU:

• It starts in five years with companies with 5,000 or more employees and a turnover of over 1.5 billion euros.
• After six years, the CSDDD applies to companies with 3,000 employees or more and a turnover of 900 million euros
• After seven years for companies with 1,000 employees or more and a turnover of 450 million euros

The Supply Chain Act Initiative has put together a few points in which the CSDDD stands out – also compared to the existing LkSG.

In principle, it is very welcome that the CSDDD represents a paradigm shift from voluntary commitments by companies to binding requirements regarding compliance with human rights and environmental/climate protection. With the CSDDD, companies must now carry out a risk assessment of their supply chains and take remedial measures if there are negative impacts on human rights and the environment.

Unlike the LkSG, the CSDDD includes the entire supply chain from the outset, including suppliers such as quarries and mines. When companies identify risks in their supply chains, these must be weighted and addressed as a priority depending on their severity. If, in addition to the risks, it is determined that damage has already been primarily caused by the company and has occurred, then the company must make reparation.

Compared to the LkSG, the CSDDD also covers more human rights and environmental protection criteria: e.g. the right to life and freedom of thought, as well as the right to food, clothing and sanitary facilities. Conversely, the CSDDD puts small and medium-sized enterprises (SMEs) in a better position than under the LkSG, since it requires that access to training and financial support are provided if necessary. Accordingly, large companies are not allowed to pass on reporting obligations to SMEs. Unlike the LkSG, the CSDDD gives those affected the opportunity to sue companies that cause damage under civil law for damages.

What is negative about the CSDDD is that initially only companies with 5,000 or more employees are covered by the directive and that there is a long transition period until companies (of different sizes) have to comply with the directive. It is important here that the German federal government must not fall behind the German LkSG when implementing the directive, which already applies to 1,000 employees and without restriction to a minimum turnover. However, Article 1 Paragraph 2 of the CSDDD applies here, which stipulates that existing protection of human rights and the environment may not be weakened through the implementation of the CSDDD.

For a detailed assessment by the Supply Chain Act Initiative, see here:

“Was liefert das EU-Lieferkettengesetz? Kurzbewertung der EU-Lieferkettenrichtlinie (CSDDD)”