From stalled negotiations on the Corporate Sustainability Due Diligence Directive to mounting industry pressure regarding EU Deforestation Regulation delays, the EU’s sustainability agenda is being reshaped in real time.

With climate transition plans on the chopping block, ExxonMobil accused of backdoor lobbying, and Commission rhetoric shifting toward "deregulation", October marks a critical turning point. The next two weeks will reveal whether EU policymakers are able to uphold their ambitious standards, or are bound to bend to internal and external pressure.

Catch up on everything you need to know, including updated timelines, industry reactions, and new civil society research, in this week’s roundup. If you'd like us to feature an upcoming event, report or other update on The Debrief, please don't hesitate to contact us via LinkedIn.

Upcoming Events

Join the launch of Beyond Transparency: Building Safe, Accessible Digital Tools for Supply Chain Accountability by Open Supply Hub on October 9, 2025 at 2:00 PM CET. This webinar will explore how digital tools can strengthen human rights due diligence and what it takes to make them safe, inclusive, and accountable to workers and communities. Register here.

Attend The Hidden Cost of Mineral Extraction: Just Transition Strategies Towards COP30 in Brazil, on 8 October 2025, online at 2PM CEST. Register here.

Corporate Sustainability Due Diligence Directive (CSDDD)

Updates:

Having failed to reach an agreement during Omnibus negotiations, the European Parliament has proposed two new options, one of which has secured far-right backing. Reporting indicates that the EPP is prepared to move ahead with its "compromise proposal" with the far right.

Last week, members of the EU Parliament failed to reach an agreement on the Omnibus during "tense" negotiations. Nonetheless, the lead negotiator Jörgen Warborn, "remains committed to the ambitious timeline" and claims the Parliament will vote in Juri on the 13th of October.

In response, Warborn has tabled two packages that "deliver on simplification." The first proposal, which has secured "far-right" support, would remove climate transition plan mandates and raise the scope of the CSRD. The second option would maintain climate transition plans and see the scope of the CSRD stay in line with the Commission's position. Notably, both packages raise the scope of the CSDDD to companies with 5000 employees and 1.5 million euros turnover.

Updated reporting reveals that the EPP is all but ready to side with the far right on option 1, in a major blow to the sustainability agenda.

See Andreas Rashe's table (below) and post for further analysis of this plan.

President von der Leyen states publicly that the EU needs "deregulation".

On October 1st, von der Leyen's speech to the Copenhagen Competitiveness Summit emphasised the importance of “deregulation” to boost growth and private investment. According to the official transcript, she said, "because when we look at simplification, we all agree we need simplification, we need deregulation."

This is a significant development, given that the Commission had "previously explicitly denied that the bloc’s “simplification” agenda is tantamount to deregulation."

See commentary from Chloé Mikolajczak on the Commission's rhetorical shift towards regulation, where she concludes "the EU is giving into the demands of a minority of companies wanting to preserve the status quo. Regulations exist for a reason, they protect our health, our rights and the environment."

New analysis by SOMO unpacks the extent of Exxon Mobil's lobbying against the CSDDD.

The research claims that the US's largest oil company has developed a four-step strategy to effectively dismantle the CSDDD. Cited tactics include directly lobbying of policy makers, using business associations and funding think tanks.

In conclusion, SOMO argues, "By bending to ExxonMobil’s threats, Trump’s tariff war, and corporate scare tactics about jobs and investment, EU institutions have undermined their own policymaking process, rewriting the law even before implementation."

Nine organisations call on EU policymakers to ensure that efforts to simplify the EU sustainability due diligence and reporting framework preserve the alignment with international standards.

Responsible business organisations, including amfori, Cascale, Ethical Trade Initiative (ETI), Ethical Trade Norway, Ethical Trade Sweden, Fair Labor Association, Fair Wear Foundation, Green button and the Social & Labor Convergence Program (SLCP), have published a joint statement ahead of the EU Omnibus vote. The statement calls on "co-legislators to make the simplification exercise both effective and meaningful for companies in their supply chains."

Further Reading:

A new survey finds approximately 75% of EU citizens say companies should be held accountable for human rights & environmental harms in their value chains.

Three quarters of the 10,861 people interviewed in this survey, commissioned jointly by Amnesty International and Global Witness, think that the EU should uphold its environmental laws.

The poll, which surveyed people from 10 European countries, also found that 58% of people surveyed support the CSDDD, compared to just 9% opposing these protections.

New data released by Global Witness finds that 483 environmental defenders have been killed or disappeared since the CSDDD was first proposed in 2022.

Global Witness calls on the European Parliament to choose to stand with defenders – not with the forces that threaten them - ahead of the crucial 13 October vote in the Legal Affairs (JURI) Committee.

Open Supply Hub published its "Beyond Transparency" report on how digital tools can advance human rights due diligence (HRDD) and strengthen support for rightsholders.

This landmark new report, written in consultation with 65 trade unions and civil society organisations, highlights "both the systemic barriers to safe participation—political repression, legal precarity, chronic underfunding—and the transformative potential of digital tools when designed with rights-holders at the centre."

Implementation timeline:

  • October 13: Legal Affairs Committee (JURI) votes on its position on the Omnibus I Package.
  • 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:

Major companies push back against another delay to the EUDR.

On October 3rd, many of the EU's largest chocolate companies penned an open letter to the Commission calling on them to "avoid using this issue [IT problems] as grounds to reopen, delay, or change the EUDR."

Signatories, including Nestlé, Ferrero, Mars and Tony's Chocolonely, claim that any further delays to the regulation will increase deforestation and “undermine industry trust in Europe’s regulatory commitments, create considerable uncertainty and compliance costs for businesses, and put forests worldwide at risk.”

On LinkedIn Andreas Raschecalls on the Commission to listen to the companies' practical solution: if firms are unable to use the IT system or face specific technical difficulties, such cases should be recognised as force majeure for both compliance and enforcement purposes.

Further Reading/Listening:

Sustainability Views' Phillipa Nuttall's take on the EUDR Delay

Highlights from the commentary include:

Companies give confirmation this is not good news for them or for deforestation. Nestlé's Manuel Schuh says, “a decision to reopen, delay or change [the EUDR] would mean that the efforts of all committed supply chain partners involved would be jeopardised. We are not talking about theory; the process of compliance has started in practice.”

Significant change in tone of US-based companies like Mondelēz International, which went from supporter of the EUDR to backing a delay.

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:

GRC hosted an expert roundtable on "Evidentiary Thresholds and Forced Labour Investigations" under the EUFLR, alongside teams from the EU Commission.

This session brought together academic, policy and legal experts, along with those with lived experience, to openly discuss and make recommendations to the EC on how they should cover state imposed forced labor in forthcoming guidelines.

See commentary from GRC's Forced Labour Project Director Samir Goswami and Professor Laura Murphy.

Further Reading:

The Customs and Border Protection Agency's recent Withhold Release Order against Giant Manufacturing Co. Ltd, a large Taiwanese bike maker, over forced labour concerns proves the efficacy of import bans.

The import ban is the result of an investigation by CBP that identified five forced labor indicators: debt bondage, withholding of wages, excessive overtime, abusive working and living conditions and abuse of vulnerability.

Freedom Fund's CEO Nick Grono unpacks the "knock-on" effects of the action, including 'Taiwan’s government has committed to supporting resolution of the allegations' and 'Merida Bicycles, the world’s second largest bike maker, has pledged to eliminate recruitment fees and compensate affected migrant workers in Taiwan.'

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:

None

Further reading:

None

Disclaimer: This newsletter is for general informational purposes only. It does not, and is not intended to, constitute legal advice.