As the clock ticks on the EU Omnibus negotiations and the application deadline for the EUDR looms, the regulations face unprecedented pressure from internal and external sources.
In response, over 300 organisations, including giants like Nokia, IKEA’s Ingka Group, and EDF, have issued a powerful joint statement urging Brussels not to water down the Corporate Sustainability Due Diligence Directive (CSDDD) or the CSRD. Their message is clear: Europe's long-term competitiveness in an era of resource depletion depends on strong, enforceable sustainability standards, not short-term rollbacks.
This edition of the Debrief also highlights two interlinking reports exposing how forced labour-tainted goods from the Uyghur Region are entering global markets. The first from UHRP tracks a surge in new air cargo routes from Ürümchi to Europe, carrying high-risk goods like electronics and auto parts; the second reveals how fast fashion giant SHEIN sources materials linked to forced labour while exploiting workers in factories lacking basic protections.
Upcoming Events
Electronics Watch: Towards fairer mineral payment practices
On Tuesday September 16th, from 2-3pm, Electronics Watch is hosting an online event titled, "Towards fairer mineral payment practices: perspectives from cooperative mining." The webinar will explore critical issues related to cooperative and artisanal miner payments, with case studies from the DRC and Bolivia.
Sign up here.
Corporate Sustainability Due Diligence Directive (CSDDD)
Updates:
300 organisations urge the EU to ‘preserve the scope and rigour’ of its sustainability regulations
In a joint statement, financial institutions, companies and advocacy groups are calling for the EU to maintain the substance of the CSDDD and CSRD, despite pressure for deregulation.
Leading corporate signatories include Nokia, IKEA parent company Ingka Group and French utility company Electricité de France.
Notes/Further Reading:
Financial Times: Rowback on EU green rules will harm companies and investors
Simon Nixon argues that a consensus is forming amongst investors, business people and policymakers that dismantling sustainability regulations to ‘alleviate the short-term costs for companies’ risks damaging rather than enhancing Europe’s long-term competitiveness.
The article posits that the Green Deal, and its accompanying sustainability disclosures, went beyond a plan to cut emissions; they were part of a necessary growth strategy for a continent that ‘lacks resources and wants to remain at the forefront of the industries of the future.’
ESG Today Op-Ed: As EU Sustainability Rules Come Under Siege, Businesses Rally to Their Defence.
The Cambridge Institute for Sustainability Leadership (CISL)'s EU Sustainable Finance Policy Lead, Tsvetelina Kuzmanova, claims that there is appetite amongst European companies for progressive ESG legalisation, which views ‘competitiveness and climate ambition' in tandem.
Kuzmanova urges the EU to reconsider allowing misinformation and lobbying from fossil fuel industries and foreign governments to shape the future of its economy. She writes: 'We have a once-in-a-generation opportunity to build a green, modern and competitive Europe — but only if we bring all businesses with us.’
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 [delayed]: Companies with 5,000+ employees and a net turnover of 1 ,500 million EUR must comply.
- From 2028 [unchanged]: Companies with 3,000+ employees and a net turnover of 900 million EUR must comply.
- From 2029 [unchanged]: Companies with 1,000+ employees and a net turnover of 450 million EUR must comply.
EU Deforestation Regulation (EUDR)
Updates: None
Further Reading/Listening:
London Review of Books: The World’s Largest Deforestation Project
Indonesia is currently pursuing the world’s largest deforestation project in the Merauke regency in West Papua. Within three years, the Indonesian government plans to convert an expanse of forests, wetlands and grasslands roughly the size of Belgium into a ‘profitable monoculture' for sugarcane and rice production.
Douglas Gerrard argues the ‘ambition and destructiveness of the development distinguish it from previous mining or agribusiness initiatives in West Papua, which has been under Indonesian occupation since the 1960s.’
As well as its extreme social cost, the destruction of Merauke would release over 780 million additional tons of CO2 into the atmosphere, ‘more than doubling Indonesia’s yearly emissions and leading to irreversible ecosystem collapse in one of the world’s most biodiverse regions.’
EU Observer: Clock ticks down on EU deforestation law as governments push for new changes
Implementation timeline:
- 30 June 2025: Country benchmarking act adopted
- 30 December 2025: Obligations stemming from the regulation will be binding for large operators and traders
- 30 June 2026: Obligations stemming from the regulation will be binding for micro- and small enterprises
EU Forced Labour Regulation (EUFLR)
Update: None
Further Reading:
New research by the Uyghur Human Rights Project documents the sharp increase in air cargo routes from the Xinjiang Uyghur Autonomous Region to Europe.
In Manifest RiskUHRP reveals that nine cargo companies have established new air freight routes between Ürümchi and cities across the EU, UK, and Switzerland since June 2024.
Each month, these ’trade corridors’ transport thousands of tonnes of goods from the Uyghur Region, known for its ubiquitous state-imposed forced labour practices, to the European market.
Cargo transported in these carriers includes “e-commerce goods”, “auto-parts” and “electronics”: all of which are documented to be at high risk of exposure to Uyghur forced labour.
UHRP is calling for implicated governments across Europe to strengthen their regulatory frameworks, close enforcement gaps and end complicity in crimes against humanity.
Landmark research by the Rights Lab, University of Nottinghamuncovers the scale of forced labour in cobalt mines in the Democratic Republic of Congo (DRC).
The Rights Lab's new report, 'Blood Batteries' is the most comprehensive study of forced labour in DRC's cobalt mining sector conducted to date. To complete their analysis, the researchers interviewed 1,431 artisanal and small-scale miners based in the DRC's colbalt-rich areas, Lualaba and Haut-Katanga provinces. Of those interviewed, 36.8% were found to be working under conditions of forced labour.
The report also found that 87.8% began working as artisanal miners due to the lack of any alternative means of survival, and that none were members of a trade union, as none exist.
The report’s recommendations include an 'independent due diligence initiative on cobalt supply chains that is conducted by Congolese academics, civil society, and artisanal mining communities, to ensure that downstream partners are adhering to national and international laws on human rights and environmental sustainability.'
Implementation timeline:
- 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:
Solar imports held at border as the Trump administration tightens enforcement of the Uyghur forced labour prevention act
A review of U.S. Customs and Border Protection data demonstrates that there has been a sharp uptick of electronics, which includes solar cells and modules, held at the border under the Uyghur Forced Labor Prevention Act since June.
June also marked the first time CBP held up polysilicon from South Korea destined for manufacturing facilities owned by Qcells, a subsidiary of Korean firm Hanwha.
Professor Laura Murphy, Former Biden Advisor on Forced Labour, said the new data indicates the administration ‘may have returned scrutiny to solar imports in June,’ having stalled detentions since October.
Further reading:
China Labor Watch's new investigative report on SHEIN exposes labour conditions within the ultra fast-fashion giant's factories.
The report "Fast Fashion, Slow Justice" reveals widespread labor exploitation in informal garment workshops located in Guangzhou’s urban villages.
Through on-the-ground visits and interviews, researchers found that workers for Shein earn as little as 7 cents per garment and frequently work for 12+ hours a day, without overtime pay or formal employment contracts.
The research also found credible risk that some of Shein's textiles contain materials sourced from the Uyghur Region, raising concerns that the company may be profiting from the Chinese government's forced labour programmes.
Disclaimer: This newsletter is for general informational purposes only. It does not, and is not intended to, constitute legal advice.