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The European Commission’s forthcoming guidance on the Corporate Sustainability Due Diligence Directive (CS3D) should:

• allow companies to voluntarily prioritise chains of activities with a meaningful connection, which should be further defined in the guidance, to the EU or based on a global risk-based approach in cases where companies have global integrated supply chains;

• recognise that companies may face conflicting or overlapping legal requirements between EU and third-country legislation, particularly in relation to information gathering, audits, data transfers, supplier disengagement and cooperation with authorities;

• clarify how companies should document and manage circumstances in which third-country law restricts or prevents a due diligence measure;

• recognise interactions with competent local authorities, regulatory inspections, permits, licences and other official approvals as potentially relevant sources of due diligence information; and

• protect companies from liability where they have followed a reasonable, documented and good-faith process, including where another stakeholder might have prioritised risks or selected due diligence measures differently.

• If these measures are included in the guidance, they would help the CS3D deliver meaningful and effective due diligence, rather than an exhaustive mapping of every global business relationship. Flexibility, proportionality and legal certainty can help companies progressively develop credible global systems while directing resources towards the most significant risks and the areas where they have the greatest ability to achieve positive outcomes.

Learn more in our contribution and paper.

Together with nine other associations, AmCham EU has signed a joint statement on the evaluation of the Single-Use Plastic Directive (SUPD), calling on EU institutions to avoid reopening the Directive. A revision at this stage would create uncertainty for operators and could also increase costs and deepen fragmentation across the Single Market. Several SUPD provisions are not yet in place. Data on implementation remain limited, making it too early to assess whether the Directive is meeting its objectives. The statement also underlines the need to address gaps in transposition and enforcement. It warns against overlaps with EU legislation such as the Ecodesign Regulation, the Packaging and Packaging Waste Regulation and the Circular Economy Act. Learn how the EU can support certainty and the Single Market in the joint statement. 

On Wednesday, 27 May, AmCham EU hosted Paulina Dejmek Hack, Head of Cabinet for Jessika Roswall, Commissioner for Environment, European Commission, for a discussion on the upcoming Circular Economy Act. Moderated by Luca Ibelli (Procter & Gamble), Vice-Chair, Environment Committee, AmCham EU, the exchange explored how the Act can support Europe’s wider simplification agenda by reducing fragmentation and strengthening competitiveness. Participants also discussed the importance of a harmonised framework grounded in a clear business case, ensuring circular economy policies help companies operate effectively across the Single Market.