Over the past two weeks, numerous developments have unfolded at the crossroads of business, trade, and human rights.
At the European level, the EU Commission is bending to US pressure on its due diligence directive as part of its trade negotiation, raising fears of a carve-out for non-EU companies. Elsewhere, new guidelines on the EU’s Deforestation Regulation confirm looming deadlines for corporate compliance, just as Brazil suspends the Amazon Soy Moratorium, opening vast swathes of rainforest to deforestation.
Meanwhile, global action against forced labour is intensifying, with the US expanding the sectors designated as high-priority under the Uyghur Forced Labour Prevention Act to critical minerals. The strength of UFLPA-style import bans in combatting forced labour has been demonstrated by new reporting documenting the growth of exports from the XUAR to the UK. This exposé reveals the fragility of the UK's existing framework and the urgent need for an approach that captures the risks of state-imposed forced labour.
Upcoming Event
The Business Human Rights Resource Centre’s New Mary Robinson Speaker Series 2025 | Big Tech vs. the public good: how human rights can detoxify tech
Tech companies occupy an increasingly dominant position in our societies, and their power, wealth and influence – from social media giants, to communications firms, to surveillance companies – are growing at pace.
In this webinar on the 11th of September at 14:00 BST, host Mary Robinson, and keynote speaker, Kenyan litigator Mercy Mutemi will be joined by an expert panel of rightsholder, regulator, and private sector voices. Together, they will identify the urgent steps needed to stop the ongoing deterioration of protections for people and democracy in the digital age, reflecting on the opportunity to re-orientate the tech sector toward the public good. Register here.
Corporate Sustainability Due Diligence Directive (CSDDD)
Update:
The new trade agreement between the US and EU spells trouble for upcoming sustainability regulations.
In its Joint Statement on the US-EU trade framework, the EU commits to 'undertake efforts to ensure that the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD) do not pose undue restrictions on transatlantic trade.’
In relation to the CSDDD this includes efforts to reduce administrative burdens on business, the elimination of civil liability and the curtailment of climate transition-related obligations.
While these measures are aligned with the Omnibus proposal, the additional commitment to “address US concerns regarding the imposition ... on companies of non-EU countries" is distinct and may signal the elimination of non-EU companies from the scope altogether.
Notes/Further Reading:
Sustainability Views’ Editor's Note critiques the EU’s decision to bow to US pressure on the CSDDD and CSRD.
Deputy Editor Elizabeth Merger claims that the EU’s assurance not to “pose undue restrictions on transatlantic trade”, could catalyse an essential carve-out for US companies from the legislation.
According to Andreas Rasche, Professor and Associate Dean at Copenhagen Business School shows that “trade is the new universal weapon used by the US to get rid of unwanted regulations.”
Implementation timeline:
- October 2025: Planned vote on the Omnibus in the Plenary of European Parliament (date TBC)
- Late 2025-2026: Trilogue on Omnibus (Parliament, Council and Commission) to negotiate final legal text.
- From 2028 : Companies with 5,000+ employees and a net turnover of 1,500 million EUR must comply.
- From 2028: Companies with 3,000+ employees and a net turnover of 900 million EUR must comply.
- From 2029: Companies with 1,000+ employees and a net turnover of 450 million EUR must comply.
EU Deforestation Regulation (EUDR)
Updates:
The EU Commission published new guidelines on the EUDR, with clarifications on timeline, due diligence obligations (Section 4) and the legality principle (Section 6).
Despite efforts to push back the EUDR timeline, the guidance confirms that the deadline for implementation for large operators remains the 30th of December 2025.
The guidelines also clarify that, while most measures are complimentary with the CSDDD, where there is conflict, the EUDR takes precedence.
Finally, the guidance defines key terms within the legislation including “negligible risk”, “operator” and the “complexity of supply chains”.
Global Canopy has released its annual Forest 500 benchmarking results for financial institutions, assessing and ranking the 150 financial institutions with the greatest exposure to deforestation risk.
The report finds that 50 financial institutions provided US$8.9 trillion to the deforestation economy through the ‘Forest 500’ companies.
Despite financial institution's leverage to influence corporate activity and transform supply chains, 60%of these bodies do not have a deforestation policy.
This finding outlines the need (and potential) for financial institutions to play their part in addressing global deforestation and supporting nature recovery.
Brazilian authorities have suspended the Amazon Soy Moratorium, a key agreement that’s protected against deforestation since 2006.
This suspension of this landmark moratorium, heralded as a global conservation success story, ‘could open up an area of rainforest the size of Portugal to destruction.’
The voluntary agreement ‘brought together farmers, environmentalists and international food companies such as Cargill and McDonald’s, and determined that any detection of soya beans planted on areas deforested after 2008 would result in the farm being blocked from supply chains, regardless of whether the land clearance was legal in Brazil.’
This move is the latest inroad by the large agribusiness lobby within the Brazilian congress in curtailing Brazil’s conservation efforts.
WWF has criticisedthe move, claiming “the Amazon is one of our best defences against climate change and we can’t afford to lose more of it.”
Further Reading/Listening:
Green Central Banking: “How deforestation threatens economic stability.”
In this article, Elena Almeida, a senior policy fellow at the Grantham Research Institute at the London School of Economics, 'breaks down how forest collapse threatens both progress towards climate goals and the foundational conditions for economic stability, productivity and public health, all of which can cascade across economies through interconnected supply chains.'
Implementation timeline:
Obligations stemming from the regulation will be binding from:
- 30 December 2025: for large operators and traders
- 30 June 2026: for micro- and small enterprises
EU Forced Labour Regulation (EUFLR)
Update: None
Further Reading:
New ILO Global Survey will shape inform research priorities on forced labour and human trafficking.
The ILO and IPA (Innovation for Poverty Action) launched a global survey to identify top research priorities on forced labour and human trafficking.
Targeting diverse stakeholders, the initiative aims to close evidence gaps and inform effective, evidence-based interventions.
The deadline for participating in the survey is 15 September 2025.
Implementation timeline:
- December 2025: Member States will confirm their designated competent authorities to the Commission and other Member States, which will be made publicly available on the Forced Labour Single Portal.
- 14 December 2025: Designation of competent authorities by Member States
- By 14 June 2026: Forced Labour Single Portal will be live.
- 2026: EU Commission to publish guidelines, including a forced labour risk database.
- 14 December 2027: Law becomes applicable.
Uyghur Forced Labor Prevention Act (UFLPA)
Updates:
The US’ Forced Labor Enforcement Task Force (FLETF) released the 2025 Updates to the Uyghur Forced Labor Prevention Act Strategy, reaffirming its commitment to eliminate goods tainted by Uyghur forced labour from the US market, including new priority sectors.
The key update is the designation of five new high-priority sectors for enforcement: caustic soda, copper, lithium, jujubes (red dates), and steel.
These additions are a credit to the years of investigative research conducted by civil society organisations dedicated to ending forced labour in the Uyghur Region, and the tireless work of Uyghur activists.
The addition of lithium to the sector list aligns with GRC’s recent contribution to this body of research, ‘Risk at the Source’which documented the industry’s extensive links to state-imposed forced practices in the XUAR.
In addition to the expanded sectors list, the FLETF announced it will prioritise the review of potential entities in high-priority sectors for addition to the UFLPA Entity List.
This announcement has expanded the enforceability of the UFLPA against critical minerals tainted by Uyghur forced labour. The FLETF’s increased focus on the critical mineral sector is essential to stalling the emergence of the XUAR as a global extractive hub and to disentangling vital industries from links to atrocity crimes.
Further reading:
Open Democracy Op-Ed: How import bans fight back against forced labour.
This think piece, co-penned by Anasuya Syam and Martina E. Vandenberg from the Human Trafficking Legal Center, defends the use of import bans, as ‘one of the only tools in the corporate accountability arsenal with real teeth’, in response to a recent article criticising their effectiveness.
They claim this critique undermines the significant changes in corporate behaviour sparked by import bans, ‘as well as tens of millions of dollars in back wages and recruitment fees returned to workers across the globe.’
The article also emphasises the criticality of import bans in addressing contexts of state-imposed forced labour, in which state collusion renders due diligence impossible.
Investigative reporting by the iPaper reveals £800 million-worth of goods have been imported into the UK from the Uyghur Region, exposing the market to complicity in state-imposed forced labour.
Throughout analysis of flight records, researchers have obtained the first detailed list of products being flown into the UK from the XUAR, which includes clothes, toys and furniture. Imports from the Region have grown substantially this year, despite widespread condemnation of crimes against humanity in the Uyghur Region.
These forced labour-tainted goods are transported directly to British airports from Xinjiang’s provincial capital Ürümqi via two UK-based airlines: European Cargo and Titan Airways.
The paper's analysis of surging imports tracks with GRC’s recent finding that exports from the Region to the UK have grown by 595.2% since 2024.
Ultimately, this news demonstrates the weakness of the UK’s current modern slavery framework and the need for a more stringent mix of forced labour prevention measures, including import bans and mandatory human rights due diligence.
Disclaimer: This newsletter is for general informational purposes only. It does not, and is not intended to, constitute legal advice.