Joining other third-country business groups, AmCham EU has co-signed a joint statement outlining concerns about the extraterritorial implications of the Corporate Sustainability Due Diligence Directive (CS3D) and the Corporate Sustainability Reporting Directive (CSRD). The letter highlights concerns regarding legal uncertainty created by certain extraterritoriality requirements in the ongoing Omnibus 1 process and outlines recommendations to ensure a clear, workable framework for all companies operating in or engaging with the EU market.
Addressing extraterritoriality in the EU’s sustainability framework
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Environmental Omnibus proposal would simplify regulatory landscape
The European Commission’s Environmental Omnibus proposal is a positive first step towards reducing the administrative and regulatory burdens on businesses operating in the EU. Key measures such as streamlining permitting, simplifying industrial emissions reporting, removing the SCIP database and easing Extended Producer Responsibility schemes would help create more efficient and harmonised processes across the EU. Additionally, the proposal’s indication of upcoming work on the Circular Economy Act and the swift implementation of the Packaging and Packaging Waste Regulation would further support a simplified regulatory environment.
By improving efficiency and predictability, the proposal would help foster a stable, investment-driven market in Europe and reinforce the case for sustainable practices. To fully deliver on the potential to reduce burdens for business, co-legislators must now move the Environmental Omnibus across the finish line. AmCham EU stands ready to serve as a resource in their efforts. These simplification initiatives in environmental regulation are crucial to maintaining Europe’s global standing as a hub for business and innovation.
The Environmental Omnibus proposal is part of the Commission’s simplification agenda and follows its proposed Chemicals Omnibus, which introduced related environmental simplifications in July 2025. These important initiatives continue to drive efforts to cut red tape, reduce regulatory burdens and enhance the EU’s competitiveness.
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Omnibus I: the EU shows it can deliver on simplification, but global firms need further certainty
The Omnibus I political agreement announced yesterday broadly eases the sustainability compliance and due diligence burden for businesses under the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD), giving much-needed certainty to businesses. It is a significant achievement for the EU’s simplification agenda and ongoing efforts to reduce the regulatory burden. Specifically, the flexibility introduced in terms of the risk-based approach and how companies need to define adverse impacts will alleviate most of the excessive burden that existed under the original CSDDD. The revised transposition timeline of CSDDD to 2029 will also give all parties the necessary time to prepare for implementation.
However, it appears that EU policymakers did not yet sufficiently tackle how these rules apply to the global activities of companies and groups – for example, by limiting the scope of the CSDDD to only those products and services with a logical link to the EU. This is a missed opportunity with far-reaching consequences that keeps legal uncertainty in place for global firms and their supply chains. This oversight on extraterritorial impact will make the CSDDD more difficult for policymakers to implement and monitor and risks creating confusing overlap with other jurisdictions’ rules.
The EU must use the next steps in the policy-making process – including implementing measures, guidance and future reviews – to fix outstanding challenges in both the CSDDD and the CSRD. In particular, clearer rules on when and how EU legislation impacts global business activities would give companies the predictability they need to invest and support sustainability investments.
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Ensuring a predictable framework for EU sustainability reporting
AmCham EU has joined 16 industry partners in urging support for the amended Taxonomy Delegated Act. With application set for 1 January 2026, any delay would create legal uncertainty and disrupt company preparations already underway. The revised rules offer simplified and more consistent reporting obligations, essential for business confidence and regulatory stability. Reopening the process now would increase costs and undermine Europe’s competitiveness. Learn why timely adoption of the Delegated Act is critical to ensure predictable implementation, maintain trust in the EU Taxonomy framework and support companies’ sustainability efforts in the joint industry statement.
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