EFFA – European Flavour Association

It welcomes the initiative and it makes some recommendations regarding the recognition of voluntary commitments and the creation of a harmonised approach.

The entity indicates: ‘EFFA welcomes this initiative as it complements the current IFRA-IOFI Sustainability Charter of which we are a signatory’. It also recommends considering the following points: ‘Recognise the voluntary commitment of companies towards the objectives set by the Commission’s proposal, as it is the case with the IFRA-IOFI Sustainability Charter. Support the creation of a harmonised approach across the EU’.

By endorsing this joint statement, the entity demonstrates support for the Omnibus Simplification Package designed to lower the level of ambition and delay the implementation of the Corporate Sustainability Due Diligence Directive.

The document states that: 'The Corporate Sustainability Due Diligence Directive (“CS3D”), undoubtedly the flagship legislation adopted under the Green Deal, is particularly ambitious in terms of its scope thereby creating challenging and impactful new obligations for businesses with global value chains and in some instances rife unintended repercussions for the real economy in the EU and in third countries. ... We, the undersigned European associations representing companies and sectors impacted by the CS3D, welcome the European Commission’s intention to put administrative burden relief and simplification at the heart of its agenda'. It also calls for extending the implementation phase: 'Guidelines and implementing legislation should be adopted at least two years before compliance with legislation becomes mandatory or the transition period should be extended'.

It calls for acknowledging the challenges and complexities of certain supply chains which can jeopardise change/remediation, and calls for the Directive to acknowledge efforts of working towards remediation.

The entity recommends that one should: ‘Acknowledge the challenges and complexities of certain (agricultural) supply chains that can make it difficult for a single company to affect immediate change / remediation. Companies' efforts to engage with their suppliers should therefore be rewarded, and the directive should acknowledge that working towards remediation is preferable to a simple disengagement’.

The signatories call for avoiding the extension of the scope of CS3D during implementation and the introduction of guidance on model contract clauses.

The statement indicates that, 'competitiveness assessment that leads to the new simplification should ensure that upcoming implementing legislation and guidance … are co-developed to address gaps or excessively burdensome provisions, rather than introduce additional layers of complexity or de facto extend the scope of the CS3D'.