The position paper appeals to co-legislators to consider the economic impact of the Omnibus proposal, as smallholders are key supply chain actors. In particular, smallholder farmers, miners and fishers face systemic challenges, including limited market access, inadequate financial resources, and insufficient infrastructure.

If adopted, the Omnibus simplification package, could risk undermining the core principles of responsible business conduct, particularly the protection and inclusion of smallholders in global supply chains. 

While we support the Commission’s efforts to streamline regulations, we are concerned about the specific changes in the Omnibus proposal that risk undermining the core principles of responsible business conduct, particularly the protection and inclusion of smallholder farmers in global supply chains. Therefore, the co-legislators should preserve the core elements of the CSDDD that enable supply chain resilience as follows:

1. Ensure that the CSDDD is aligned with international standards, i.e. the OECD Guidelines and the UN Guiding Principles on Business and Human Rights. (...)
2. Ensure companies engage in responsible disengagement if they decide to terminate contracts with smallholders.
3. When companies in scope conduct risk mappings in their supply chains, ensure that they request information from suppliers that is proportionate to the prevalence and type of risks anticipated, and that the data requests are targeted and collaborative.
4. Incentivise stakeholder engagement at relevant stages of the supply chain and the due diligence process, supported by NGOs.
5. Ensure a harmonised civil liability regime.

Read the full position paper here.