JBCE co-signs a Joint Statement on the Extraterritorial Aspects of the Omnibus I Proposal

04/11/2025

On 4 November 2025, the Japan Business Council in Europe (JBCE), together with the American Chamber of Commerce to the EU (AmCham EU), the European Australian Business Council (EABC), the Europe India Chamber of Commerce (EICC), and the Korea International Trade Association (KITA), co-signed a joint statement addressing the extraterritorial implications of the Omnibus I proposal amending the Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CSDDD).

The statement raises concerns about the potential legal and practical uncertainties arising from the extraterritorial application of both directives and calls for a clear, proportionate, and globally coherent implementation framework for non-EU companies.

In particular, the statement highlights the following key points:

• Clarifying jurisdiction and scope (CSDDD)
  The statement calls for a clearer definition of the applicable scope based on a company’s substantial business presence or activities within the EU to prevent excessive extraterritorial reach. It also recommends that litigation jurisdiction should be limited to cases with a clear and direct link to the EU, thereby reducing the risk of multiple or overlapping lawsuits.
• Adjusting reporting obligations and ensuring adequate transition periods (CSRD)
  The co-signatories propose to clarify the EU nexus in determining reporting obligations and to provide sufficient preparation time for non-EU parent companies through an extended transition period. They also urge the early adoption and publication of the Non-EU Sustainability Reporting Standards (NESRS) to facilitate consistent compliance.
• Ensuring international alignment
  The statement emphasizes the importance of aligning the EU framework with established international standards, such as the OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights (UNGPs), to support effective and non-duplicative sustainability practices by global companies.

JBCE and the co-signing associations reaffirm their support for the objectives of the CSRD and CSDDD, while encouraging EU policymakers to ensure legal certainty, proportionality, and international coherence in the implementation of the EU’s sustainability legislation.

 

For more information, please contact:

Nagisa Kagawa

Policy Manager (CS)

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