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23 May 2022

German Institute for Human Rights (GIHR)

German Institute for Human Rights provides feedback on the EU Commission's proposal on Corporate Sustainability Due Diligence

The German Institute for Human Rights (GIHR) welcomes the European Commission‘s proposal on Corporate Sustainability Due Diligence (EU CSDD). Europe-wide regulation will help to improve respect for human rights along supply chains. Individual EU Member States have already advanced the regulation of supply chains at national level, including Germany with its „Act on Corporate Due Diligence Obligations in Supply Chains“, which will enter into force in 2023. While comparable in many provisions, the EU Proposal goes beyond some provisions in the German Law.

The GIHR believes that the Proposal has a potential to have a significant positive impact on people and planet. However, this can only be achieved if companies engage with it in a meaningful way. There is a risk that some features of the law will undermine its effectiveness and foster “checkbox compliance”.

The GIHR makes comments on the Proposal with regards to the following elements in the attached file:

  • Scope of value chain
  • Due diligence in "established business relationships"
  • Scope of companies covered
  • Civil Liability
  • Administrative enforcement

See here for the submission of the Danish Institute for Human Rights, the Danish national human rights institution.

All feedback to the EU Commission survey on its proposal is available here.