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EU: Companies speak out after Evian letter attempt to undermine CSDDD

Amid 'Omnibus' negotiations – with proposals to scale back the Corporate Sustainability Due Diligence Directive (CSDDD or CS3D) and other key legislation – a letter sent by the CEOs of TotalEnegies and Siemens to President Macron and Chancellor Merz made headlines in October, mainly due to its claim that "CEOs call for the full abolishment of CS3D as a clear and symbolic signal". Signed only by TotalEnergies and Siemens, the letter still implied it was "in the name" of 46 CEOs participating in the 2025 Franco-German business meeting in Evian, France.

This stands in stark contrast to broad business support the CSDDD has received to date. Also, reporting from Politico and Tagesspiegel Background suggested soon after the letter's release that its exact circumstances and backing were unclear. The CEO of Bpifrance said "he did not see it before it was published, and therefore doesn’t consider that he signed it." Amundi stated they "neither participated nor signed a letter", while Allianz, Deutsche Bank and KfW all confirmed they continue supporting the CSDDD.

Meanwhile, TotalEnergies claimed they and Siemens had been encouraged by the two heads of state to "express their priorities" as meeting co-chairs. Siemens said the proposal to abolish the CSDDD was "cited as an example" in the letter.

Against this backdrop, Business & Human Rights Resource Centre, together with Social LobbyMap, reached out to another 10 French (5) and German (5) companies represented at Evian from across different sectors to ask them for clarification. Our main question was: "Is it your company’s position to call for the full abolition of the CSDDD?"

None of the 9 companies that provided a response said they are in favour of abolishing the CSDDD. Rather, companies renewed their support for the CSDDD, stressing why it matters and highlighting certain aspects like a pragmatic and risk-based approach (click on company names for full comments):

  • Danone stated they did not take part in drafting or signing the letter, which therefore "should not reflect any consensus on the topic". The company also confirmed it "does not support the abolition of CSDDD and remains committed to the intent of it.”
  • SAP said the letter "was not aligned with SAP" and CSDDD is "a crucial step toward harmonized rules and a level playing field [...] but at the same time needs to be workable for businesses." SAP specified "[w]hy CSDDD matters", citing legal clarity and alignment, responsible value chains, and long-term competitiveness: "Strong due diligence builds resilience, reduces risk exposure, and responds to investor and market expectations."
  • BNP Paribas also confirmed they are not a signatory of the letter and stated: "[W]e believe it is important to preserve the ambition of the CSDDD and the CSRD, while also recognizing that a more pragmatic approach and simplification are essential for effective and efficient implementation".
  • Michelin said that the company is "not calling for the abolition of the CS3D, whose principles it supports."
Why CSDDD matters ∙ Legal clarity and alignment: It replaces fragmented national approaches with a single, predictable EU-wide standard. Responsible value chains: It ensures that companies identify and address negative human rights and environmental impacts. Long-term competitiveness: Strong due diligence builds resilience, reduces risk exposure, and responds to investor and market expectations.
SAP in their response
  • "Regarding CSDDD", BASF stressed that they have "consistently argued that regulation should be effective and practicable. A single, well-designed European regulation is preferable as a level playing field to a patchwork of national rules.”
  • ENGIE said their position is to "favor simplification, clarification, and consistency in legislation, rather than its outright removal." The company referred to its response to the Commission's Omnibus I proposal, "which makes no mention of a request to withdraw European legislation", and added that it "remains a strong supporter of the objectives of the European Green Deal".
  • BMW Group commented that regarding the CSDDD, they are "in favor of harmonizing supply chain due diligence obligations within the EU and ask for a realistic and pragmatic directive with a clear focus on reducing administrative burdens."
  • "Regarding the necessary regulatory framework", RWE noted "it's crucial for it to be designed in a pragmatic and uniform manner. We welcome all considerations at the European level [...] to pursue a risk-based and proportionate approach without imposing excessive bureaucratic burdens."
  • While Heidelberg Materials did not directly mention the CSDDD, the company said it "is fully committed to its climate targets and sustainability roadmap", including 2030 and 2050 emmissions targets. The company also expressed support for EU emissions trading and a "timely implementation of a robust Carbon Border Adjustment Mechanism (CBAM)" [while the Evian letter had called for a CBAM "freeze"].

Full responses are available in the timeline below. AXA indicated that they will not comment on the letter.

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