Making human rights due diligence a legal requirement for companies including systems to identify, assess, mitigate or manage human rights risks and impacts to improve that process over time and to disclose the risks and impacts, the steps taken and the results.
Michelin supports the introduction of a mandatory due diligence law at the EU level that provides legal certainty, takes a risks-based approach, and ensures a level playing field.
In response to Q2: "Yes, an EU legal framework is needed." - "An EU legal framework would ensure level playing field between practices in the different Member States, but would also enable to cover non-EU undertakings providing goods and services in the EU. If companies are already often involved in a long-term sustainable governance, a regulatory approach, provided it ensures legal certainty, focuses on risk-based approach, notably on due diligence, can help make progress."
This joint statement signed by the CEOs of TotalEnergies SE and Siemens AG calls for the abolition of the CSDDD on behalf of the entities attending the 2025 Evian conference which includes this entity. There is no evidence of the entity stating support for the statement, it is added for clarification but the assessment is not part of the organisational score for this entity.
"CEOs call for the full abolishment of CS3D as a clear and symbolic signal to European and international companies that the governments and the Commission are really engaged to restore competitiveness in Europe."
Following the Evian letter in October 2025, the Business and Human Rights Centre reached out to Michelin to ask their position on the CSDDD. Michelin restated its support for the principles of the EU due diligence law, and confirmed that it does not support calls for its abolition.
"Michelin is not calling for the abolition of the CS3D, whose principles it supports. The Group has been exercising its duty of care for many years and will remain strongly committed to this issue regardless of the regulatory framework."
Requiring Human rights due diligence of all companies, regardless of sector and size, while still reflecting their individual circumstances.
Michelin supports the inclusion of all companies in the scope of due diligence obligations, including all sectors, non-EU undertakings, and SMEs; with proportionate responsibilities and reporting for the latter.
In response to Q15, "diligence obligations should be applicable across all sectors."
Q16, "SMEs should be subject to lighter requirements ... SMEs should have lighter reporting requirements."
Q17, "Ensuring that non-EU undertakings are also concerned by the legislation is necessary to implement a level playing field. A criteria of minimum global turnover of the company (250 million euros for example) would be the most relevant option."
Implementing an enforcement mechanism where companies fail to carry out due diligence as described.
Michelin supports effective enforcement of the CSDDD at both the national and EU levels. The entity emphasises the need for Member State coordination and for sanctions to be proportionate to the level of breach and scale of influence that the company has over its suppliers and contractors.
In response to Q19a on enforcement of the CSDDD, Michelin selected option 3, "Supervision by competent national authorities with a mechanism of EU cooperation/coordination to ensure consistency throughout the EU" - "Cooperation between Member States is always necessary, especially to ensure the same understanding and implementation of the rules. Also, corrective measures should be looked for as a first step before any sanction, to help companies effectively implement due diligence. Sanctions should also be modulated according to the level of breaches. For instance, if the whole supply chain was to be considered in the legislation, then there should be a different application of sanctions in case of a breach in tier one suppliers or beyond, as beyond tier one is much more difficult to control and evaluate for a company. In the same spirit, the capacity of the company to influence its suppliers and to mitigate risks in the supply chain should be taken into account. "
Enabling judicial enforcement with liability and compensation in case of harm caused by not fulfilling the due diligence obligations.
The entity calls for enforcement of due diligence obligations beginning with allowing companies the chance to take corrective actions, followed by sanctions where necessary. However, the company does not call for the inclusion of civil liability or judicial enforcement.
In response to Q19a on enforcement of the CSDDD, Michelin did not select "Judicial enforcement with liability and compensation " as an option.
Require companies to implement a due diligence process covering their value chain to identify, prevent, mitigate and remediate human rights impacts and improve that practice over time.
Overall, Michelin supports the definitions and scope proposed in the CSDDD in relation to value chain. The company does request more clarity and states that in practice, due diligence should begin at tier one, but it supports a risk-based approach and does not ask for the scope to be limited.
In response to Q14, "Michelin globally agrees with this definition, which takes into account the notion of “risk-based approach”, which is at the core of any efficient action. Moreover, the notions of proportionality, context specificity and reasonable efforts are in line with what companies can do. However, the scope of the definition needs to be precise and the notion of setting priorities should be included. As a first step, due diligence obligations should focus on tier one suppliers; indeed, in a supply chain such as ours, which includes natural rubber, made of hundreds of thousands of small farmers, having full control of the whole supply chain is highly difficult. It should also be clarified that companies can only be responsible of companies within their value chains. For instance, a company cannot have view on the independent sister company of a supplier."
Require that companies identify their stakeholders and their interests.
Michelin highlights the relevance and importance of taking stakeholder interests into account when making company decisions; however, the company does not support the introduction of directors' duties in relation to stakeholders. It is unclear what Michelin's position is for a wider company requirement to identify stakeholders and their interests, rather than making it a specific director's duty.
In response to Q5 on interests that are relevent to the long-term success of the company, Michelin selected "employees", "persons and communities affected by the operations of the company", and "persons and communities affected by company's supply chain" as "relevant".
In response to Q6, which asks, " Do you consider that corporate directors should be required by law to identify the company´s stakeholders and their interests" the company responded, "I do not take a position" - "Michelin firmly believes that taking into account interests of the different stakeholders of the company is a necessity, and puts this belief into practice notably with a stakeholders’ dialogue. However, we don’t believe that requiring these actions by law to corporate directors should be either efficient or adapted."
Require directors to establish and apply mechanisms or, where they already exist for employees for example, use existing information and consultation channels for engaging with stakeholders.
While Michelin supports stakeholder engagement, and outlines the steps that it has taken to ensure effective channels of dialogue, the company does not believe that it should be mandatory for companies to provide grievance mechanisms for all stakeholders. Rather, it should be left to the individual company to decide the best mechanisms for engagement.
In response to Q20a, which asks, "Do you believe that the EU should require directors to establish and apply mechanisms or, where they already exist for employees for example, use existing information and consultation channels for engaging with stakeholders in this area?", Michelin responds, "I disagree to some extent" - "Michelin is fully committed to ensuring that stakeholders’ views are part of the strategy of the company. That is why we have established a stakeholders’ committee at Group level. Moreover, some regional Michelin entities are developing, in the same dynamic, regional stakeholders’ committees, in order to structure their local stakeholders’ dialogue. This shows that this kind of dialogue, necessary to understand the views and issues of the stakeholders concerned by the company’s choice, must be adapted to the specificity of the undertaking."
Q20c, "We believe that setting up a body to take into account views from the different stakeholders of the company must be efficient, and must help the company to have a comprehensive understanding of the issues at stake. That is why we should leave the company decide what are the mechanisms it finds adapted to its own situation."
Require that human rights risks and impacts should be assessed through dialogue with stakeholder or with their legitimate representatives.
Michelin believes in the importance of stakeholder dialogue; however, they do not support including this as a legal requirement under the CSDDD.
In response to Q6, "Michelin firmly believes that taking into account interests of the different stakeholders of the company is a necessity, and puts this belief into practice notably with a stakeholders’ dialogue. However, we don’t believe that requiring these actions by law to corporate directors should be either efficient or adapted." Q7, "We do not believe that targeting corporate directors is the right way to ensure the company has the right procedures when it comes to risks linked to stakeholders. A risk-based approach is part of the strategy of the company."
Require that corporate directors should manage the human rights risks for the company in relation to stakeholders and their interest including on the long run.
Michelin believes in the importance of taking stakeholder interests into account; however, they do not support the introduction of provisions that would establish a director's duty to do so.
In response to Q6, which asks, "Do you consider that corporate directors should be required by law to manage the risks for the company in relation to stakeholders and their interests, including on the long run", the company responded "I do not take a position" - "Michelin firmly believes that taking into account interests of the different stakeholders of the company is a necessity, and puts this belief into practice notably with a stakeholders’ dialogue. However, we don’t believe that requiring these actions by law to corporate directors should be either efficient or adapted." Q7, "We do not believe that targeting corporate directors is the right way to ensure the company has the right procedures when it comes to risks linked to stakeholders. A risk-based approach is part of the strategy of the company."
| Legislation | Position |
|---|---|
| EU CSDDD | Neutral/Mixed |
| Omnibus | Not Supporting |
| Trade Association | Performance band |
|---|---|
| Cobalt Institute | C+ |
| Association Nationale des Sociétés par Actions (ANSA) | E |
| AFEP | E- |