Eurogas

By endorsing this joint statement, the entity demonstrates support for the Omnibus Simplification Package designed to lower the level of ambition 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'.

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

Based on the document "How simplification can drive ambition, reduce burden, and strengthen Europe’s competitiveness, June 2025" in which Eurogas is listed as a signatory, it states: "The proposed Simplification Omnibus Package represents a crucial opportunity to restore regulatory clarity and enable meaningful action on the ground." "As representatives of sectors essential to the energy transition, industrial innovation, and Europe's economic resilience, we call on policymakers to safeguard and reinforce the simplification measures proposed-and to resist any efforts to reintroduce complexity." "Currently, the interplay between the CSRD, CSDDD, and the EU Taxonomy creates a fragmented and burdensome landscape. Overlapping, overly prescriptive and detailed disclosure and due diligence requirements risk shifting high skilled resources away from real-world impact and toward navigating compliance complexities. The proposed Simplification Omnibus Package represents a timely and necessary opportunity to restore clarity and enable meaningful implementation."

The entity, through a joint business statement (JBS), shows support while showing some concerns on implementation.

The JBS indicates that: 'European business remains supportive of the objectives of the proposed directive ... and we urge co-legislators to work on a reasonable approach that is manageable for companies in practice'. It also states that 'we strongly call for full harmonization to ensure a level playing field and avoid further internal market fragmentation' and that 'legal clarity is paramount for the success of this initiative'.

The JBS does not oppose the inclusion of SMEs, but calls for safeguards to protect them.

The JBS seem to show support to the inclusion of SMEs, although it reiterates that: "The European economy, included SMEs which will be impacted even if formally out of the scope, need a workable due diligence framework that is drafted in a balanced and proportionate way."

The entity has not made any further statements on enforcement mechanisms. By endorsing this statement, they demonstrate that they support the simplification of an enforcement mechanism (here civil liability).

Based on the document "How simplification can drive ambition, reduce burden, and strengthen Europe’s competitiveness, June 2025" in which the entity is listed as a signatory, it states: "We welcome the removal of the harmonised EU civil liability regime under Article 29 of the CSDDD. However, residual elements, such as joint liability, broad evidentiary obligations, and unclear thresholds for disclosure, still undermine legal certainty and contradict the Commission’s own simplification objectives." "We believe that, to maintain coherence and subsidiarity, civil liability should be governed by national systems."

By endorsing this statement, the entity demonstrates that they oppose the regulation of directors' duties in a due diligence framework.

The signed joint business statement states, "Regulating directors’ duties does not belong in a due diligence framework. It will have negative side-effects, including the disruption of existing, well-established governance models of the member states, without added value to the ability of companies to apply effective due diligence. "

The JBS rejects including directors' duties in the Directive.

The JBS states that: 'regulating directors' duties does not belong in a due diligence framework. It will have negative side-effects, including the disruption of existing, well-established governance models of the member states, without added value to the ability of companies to apply effective due diligence'.

By endorsing this statement, the entity demonstrates that they support the simplification of liability duties, oppose EU harmonised civil liability, and call for the deletion of Article 29 of the directive.

Based on the document "How simplification can drive ambition, reduce burden, and strengthen Europe’s competitiveness, June 2025" in which the entity is listed as a signatory, it states: "We welcome the removal of the harmonised EU civil liability regime under Article 29 of the CSDDD. However, residual elements, such as joint liability, broad evidentiary obligations, and unclear thresholds for disclosure, still undermine legal certainty and contradict the Commission’s own simplification objectives." "We believe that, to maintain coherence and subsidiarity, civil liability should be governed by national systems." "We call for the deletion of Article 29 of the CSDDD"

Although the joint statement does not oppose to legal liability, it calls for a more balanced approach

The joint statement indicates that 'Legal liability provisions, including sanctions, need to be balanced, follow legal traditions around breach-damage-causality and truly incorporate the widely accepted principle that due diligence is first and foremost an obligation of means. The complexity of value chains cannot be underestimated when analysing impacts which can have multiple competing causes, players and dynamics. Therefore, companies cannot be made liable for damages they have not -intentionally or negligently - caused'.

By endorsing this statement, the entity demonstrates that they question the feasibility of a due diligence process covering the value chain and support reducing the scope of the proposal.

Based on the document "How simplification can drive ambition, reduce burden, and strengthen Europe’s competitiveness, June 2025" in which the entity is listed as a signatory, it states: "companies could be held accountable for harms caused exclusively by independent partners several tiers down the value chain, even when they have taken all due measures under the Directive. This disincentivises engagement, creates litigation exposure, and duplicates existing national liability frameworks." "Obtaining granular ESG data from these suppliers, especially SMEs or those in jurisdictions with different legal systems, is often not just difficult, but impossible. Companies report that suppliers are increasingly unwilling to disclose information due to commercial sensitivity or regulatory conflict. We welcome the introduction of a value chain 'cap' and recommend further clarification on what constitutes “commonly shared information” and how proportionality principles will apply — particularly for non-EU data collection. Without this, the reporting burden may result in unintended supplier disengagement and "concentration risks"

The joint statement argues that companies can't focus in all elements of their value chains. It also calls for a reduction of obligations

The joint statement states that 'To ensure that the future Directive is truly consistent with a risk-based approach, widely supported in international instruments in the UN and OECD, companies cannot be expected to focus on every single element of their value chains. The ability to prioritise the identification of and action to address the most salient risks is a necessity that must have a crucial impact on compliance with the due diligence process and its consequences'. It also points out that 'we call for revisiting and shortening the annex to only include those conventions and treaties that create concrete obligations on companies so not to mix up their roles with the one of states'.

The signatories call for avoid the extension of the scope of CS3D during implementation and 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'.