EFF: The Omnibus Package - The Way Forward on Simplification & Sustainability Rules

Summary

Highlights

• The omnibus package proposes significant reductions in mandatory sustainability reporting obligations. 📉
• Smaller companies are to be shielded from excessive data requests due to their position in larger companies' value chains. 🔗
• The corporate sustainability due diligence directive is set to limit obligations primarily to direct suppliers, raising concerns about deeper supply chain risks. 🔍
• The package has sparked discussions on balancing bureaucratic burden reduction with maintaining competitiveness and sustainability. ⚖️
• Many stakeholders call for sector-specific guidelines to help industries navigate new regulations effectively. 📑

Key Takeaways

• Simplifying regulations is essential to enhance European competitiveness and support the economy. 🏗️
• The new omnibus package focuses on reducing administrative burdens for businesses, especially in the food sector. 🍽️
• A balance must be struck between regulatory simplification and achieving sustainability goals. 🌍
• Stakeholders have mixed reactions to the potential impacts of limiting reporting to 'tier one' suppliers. 🤔
• Smaller companies might benefit from reduced scope, but there's worry about the trickle-down effect of compliance demands. 🏢
• Civil society emphasizes that sustainability and competitiveness are interconnected and should not be viewed as opposing forces. 🔄

Overview

Chapters

• 00:00 - 03:00: Introduction and Event Overview The chapter introduces the European Food Forum's event focused on the omnibus simplification package. Agata Yascot, the government affairs lead at Bangi, welcomes the audience to the event. The introduction sets the stage for discussions on the simplification package and hints at the complexity and involvement of many stakeholders in the process, as reflected by Yascot's role as just one of many in the initiative.
• 03:00 - 05:00: Welcome Remarks and Introduction of the European Food Forum The chapter provides welcome remarks and introduces the European Food Forum. It highlights the role of the moderator, who will guide the discussions on the simplification package related to European affairs. The discussion aims to explore the current happenings, reasons for initiating the simplification now, and the expectations of various stakeholders.
• 05:00 - 11:00: Opening Remarks by Honorable Members of European Parliament The chapter titled 'Opening Remarks by Honorable Members of European Parliament' discusses the evaluation of the omnibus simplification proposals. The focus is on assessing their direct impact on the food sector and the broader implications for civil society and citizens. It is mentioned that there will be two panels: the first will concentrate on the regulatory feasibility and impact by providing an overview of the omnibus initiative and its implications.
• 11:00 - 45:00: Panel 1: Regulatory Feasibility and Impact of the Omnibus Package The chapter titled 'Panel 1: Regulatory Feasibility and Impact of the Omnibus Package' covers a discussion that starts with the presentation of industry perspectives. Stakeholders affected by the regulations offer insights into the feasibility and potential impacts of the new omnibus package. The discussions aim at achieving a balance between regulatory goals and industry capabilities. Finally, the panel concludes with a conversation drawing conclusions and proposing next steps for implementation, boasting an audience of over 80 participants.
• 45:00 - 79:00: Panel 2: Business and Civil Society Perspectives on the Omnibus Initiative The chapter titled 'Panel 2: Business and Civil Society Perspectives on the Omnibus Initiative' begins with an introduction to the European Food Forum. It is described as an independent, politically led, and nonpartisan multistakeholder forum, founded and governed by elected members of the European Parliament. The forum aims to facilitate open dialogues among various stakeholders to promote competitive, resilient, sustainable, and innovative food systems, focusing on policy discussions.
• 79:00 - 92:50: Q&A Session and Audience Interaction The chapter titled "Q&A Session and Audience Interaction" opens with an introduction to the participants involved, including stakeholders, food supply chain actors, civil society organizations, research academia, and other public institutions. It is emphasized that the European Food Forum does not take a stance on specific policy issues but instead focuses on facilitating open and meaningful discussions on important topics. The chapter also includes organizational notes, mentioning there will be an open Q&A session.
• 92:50 - 116:30: Closing Remarks by MEPs and Conclusion of Event The chapter provides guidance for participants on how to ask questions during the debate. Participants in person can raise their hands, while online participants are encouraged to use the chat function. It is emphasized that questions should be brief, with a maximum length of one minute. Additionally, attendees are reminded that the event will be recorded.

EFF: The Omnibus Package - The Way Forward on Simplification & Sustainability Rules Transcription

• 00:00 - 00:30 [Music] [Music] [Applause] [Music] uh welcome to European Food Forum's event on the omnibus uh simplification package i'm Agata Yascot um government affairs lead at Bangi um you can only imagine I'm just one of the many you
• 00:30 - 01:00 affairs professionals that are following the um simplification package uh but today I'm privileged to wear the moderator's hat um and um I will guide you through our discussions on the way forward on simplification um together we will untangle what is happening why now and what are the expectations um from the various stakeholders that
• 01:00 - 01:30 are here present with us um we will evaluate the pros and cons of the omnibus simplification proposals and their direct impact specifically on the food sector as well as on the broader implications for the civil society and uh citizens so we will have two panels our first panel will be dedicated to the regulatory feibility and impact providing an overview of the omnibus initiative and its implications in the
• 01:30 - 02:00 second panel you will have industry perspectives um presented to offer insights from stakeholders affected by these regulations and finally we will have discussions um concluding discussions where we will have a conversation on achieving the balance drawing conclusions and proposing the next steps for implementation um this leads me to proudly announce that we have um an audience of over 80
• 02:00 - 02:30 participants today both in present and online um and before we start I just wanted to uh say a few words on the European Food Forum um it is an independent politically led and nonpartisan multistakeholder forum founded and governed by elected members of the European Parliament eff aims to promote open multistakeholder dialogues on competitive resilient sustainable and innovative food systems among policy
• 02:30 - 03:00 stakeholders food supply chain actors civil society organizations research academia and other public institutions um please do note that the European Food Forum does not itself take any positions on specific policy issues um but rather aims to foster a meaningful open discussion on relevant topics um just a couple of organizational remarks there will be a Q&A session um this is an open
• 03:00 - 03:30 debate so every participant can ask questions um by raising your hands uh for those of you who are online uh please do not be shy and use your um use the chat function um just please please um do uh remember that your question should be no longer than 1 minute uh um also uh the event will be recorded and please do um take into consideration
• 03:30 - 04:00 that we have journalists among us um having said this um I'm grateful to the organizers for making this very important exchange happen today um thank you for your time and effort by uh for bringing together such a um distinguished range of panelists an equally big thank you to our hosts um honorable members of the European Parliament Elena Donatan uh deputy chair of the IT committee um and um uh Petroi
• 04:00 - 04:30 deputy chair of the Envy Committee uh both from the European Conservatives and Reformist groups um Mr natan um I will um start I will therefore ask you to kindly uh share with us your your opening remarks thank you very much and excuse for our late but today is a very busy busy day and plenty of uh meetings
• 04:30 - 05:00 let me thanks uh also my colleagues that are here i see my colleague at Picaro and then in Selvini and Vivaldini and Chirani all yes I think I don't understand I I yes I mentioned all thank you and also thanks to my colleague Fi that has involved me uh to organize this meeting with you uh please one more and at the end thanks to Louisa Chani
• 05:00 - 05:30 because she's very active here and uh and today we can uh put the our attention to the a very big topic uh about uh about the agenda and about the omnis package so let me start with some few consideration also because we are uh always uh uh for as is normal to speak for one minute so today for me speaking for more than one minute is a very is a
• 05:30 - 06:00 gift thank you uh so um uh last September Mario Draghi published a decisive report warning us about the absolute necessity of growth and competitiveness of our continent he made it clear if the European Union does not change a course it will not be a leader in a new technologies nor an independent player on the global stage to prevent Europe from f falling behind in terms of growth
• 06:00 - 06:30 and competitiveness we must act strong and fast we must support our economy we need growth and not bureaucracy this is what will drive our economy forward and also enable to green uh to go to the green transition to achieve this we must first provide the clarity to our European businesses and deliver concrete results this is why a change is needed european
• 06:30 - 07:00 Commission's new omnibus package is a step in the right direction it is a late but a necessary recognition that excessive regulation has been holding our businesses back the ambibus package aims to enhance European competitiveness by simplifying regulations it introduces legislative changes to the US green deal rules offering companies a much needed competitive advantage these regulatory
• 07:00 - 07:30 cuts known as omnibus include the following key measures first corporate sustainability reporting directive the scope of this directive will be significantly reduced removing 80% of coms from its requirements only business only businesses with over um 100 no not 100,000 sorry in in very
• 07:30 - 08:00 difficult different employees will still be subject to a mandatory sustainability reporting carbon board and adjustment mechanism known as a sebum uh the reporting obligation for 10% of affected companies will be simplified making CO2 value calculations more flexible third EU taxonomy the commission will narrow its scope
• 08:00 - 08:30 reducing reporting obligations for businesses with a fewer than 1,000 employees the reporting burden will decrease by 70% allowing companies to focus on truly impactful sustainability efforts fourth corporate sustainability due diligence directive the revised proposal eliminates the requirement to terminate business relationships in case of persistent human rights or environmental
• 08:30 - 09:00 violations additionally compliance deadlines are extended and reporting barness are significantly reduced at the end invest this investment program will receive a major boost unlocking an additional of 50 billion in public and private investment one of the sector that will greatly benefit from this simplification is the food ind food industry europe's food producers manufacturers and
• 09:00 - 09:30 distributors have long struggled under heavy regul regulatory burdens that limit their efficiency and global competitiveness reducing unnecessary bureaucracy bureaucratic requirements will allow businesses in the fuel sector to focus on innovation sustainability and de delivering high quality products to consumers red the reduction of obligation under
• 09:30 - 10:00 this omnibus package will help small and mediumsiz of food businesses avoid excessive administrative costs and redirect their resources toward productivity far for far too long European businesses have been burdened with excessive bureaucracy if we want a more competitive Europe and to ensure the survival of our businesses we must cut the right tape however we
• 10:00 - 10:30 can and must go even further in simplification legislative and our group as we know our uh member here are all from ECR group will advocate for additional measures in the upcoming negotiation negotiations and the discussion within the parliament that is why moment like this are u this one are pivotal in our job i really want to
• 10:30 - 11:00 thank the European food forum for organization this seminar uh only through an open discussion between us policy maker uh who will be shortly called to work on this package our institutions representative and stakeholders from the food industry sector we can truly understand what works and what must be changed thank you i look forward the discussion and all the best for the success of this seminar
• 11:00 - 11:30 all right thank you very much um we can proceed now to the first panel um I would say it's it's pretty self-explanatory we have titled it setting the scene on regulatory feasibility and impact an overview of the omnibus initiative um and we'll start we'll have three speakers in the panel um we will start with Tyman Deise
• 11:30 - 12:00 uh managing partner ESG and international value chains at Chutelar and partners um we will have Martin Merlin director of financial markets uh from directorate general for financial stability financial services and capital markets union so DG FSMA and we will have Alexandra Palinska executive director at URIF the European Sustainable Investment Forum
• 12:00 - 12:30 um I will proceed i think we we can show already the slides and and given the Sorry please go ahead no also uh myself I have to uh say uh thank you to Louisa Chani uh the bag with 600,000 euro in black money was delivered to my house and uh my wife was very happy i'm joking she never even offer me
• 12:30 - 13:00 a coffee no this is an extremely important topic uh we need to consider it from a strategic point of view because uh Europe is importing everything uh animal feed [Music] uh fertilizers the rain and everything else so we need to reconstruct the agricultural base to go toward a European food uh produced in
• 13:00 - 13:30 Europe right now we import everything so this is very important and I'm very happy to be here to co-chair with Failen uh this uh exchange of views thank you okay thank you very much um we can proceed now with the with the first presentation uh so Tyman looking very much forward to your um to you explaining to us a bit what has happened
• 13:30 - 14:00 what is included in the omnibus simplification package um and and what could be the potential impact thank you and thanks again for the invitation uh from the European food forum and yeah happy to uh exchange thoughts um I think the presentation is starting or uh yeah is yeah all right perfect there we are it makes it a bit easier to follow um so first of all yeah thanks
• 14:00 - 14:30 again for the uh invitation um if I can navigate through all right so first of all to set the scene a little bit as as said um the next slide please all right so a timeline from the omnibus and we all know that uh on the 26th of February uh the omnibus one was published which contains of course yeah
• 14:30 - 15:00 it's a package let's say containing the CSRD corporate sustainability reporting directive CSD uh which is the due diligence directive taxonomy uh but also CBAM carbon border adjustment mechanism as said but there is a little bit of history before and it's worth mentioning the draggy report was mentioned of course an influential report uh in itself but already uh on the 18th of July as part of the new uh uh guidelines the political guidelines of the new commission uh it was said that it's
• 15:00 - 15:30 clearly needed to make businesses easier and faster in Europe in other words uh um really getting rid of administrative burdens less red tape less reporting and more trust and better enforcement so that was the uh the kickoff so you will uh then on the 19th of September September or 9th of September the drugy report was mentioned really raising the EU competitiveness u as as a necessary precondition for green growth in Europe obviously not letting go of the green
• 15:30 - 16:00 deal in itself and that's worth mentioning it's also something that the companies we work for feel quite strongly about that we should definitely not let go of of those ambitions um then uh uh President Urslay on the 26th of November really outlines the intention to publish um an omnibus package and as we now know it's not only one package it's actually a series and so the first two were published and the first one is on sustainability which we
• 16:00 - 16:30 will cover mostly in this presentation and um I think it's nice to cover both uh CSRD in more detail and the CSD so the reporting regulation and the due diligence regulation also in sake of time i'm mindful of my uh speaking slot so next slide please all right so what's at the table and um next slide please all right so first looking at
• 16:30 - 17:00 CSRD so again the corporate sustainability reporting directive and also the underlying ESRS which is the uh European sustainability reporting standards and so you have the legislation itself and underneath uh the reporting requirements um so first of all uh in the proposal a two-year delay for companies that have not yet reported which are called wave two and wave three um actually currently reports are coming
• 17:00 - 17:30 out wave 1 which are large listed companies so these are large companies uh and small medium-sized listed companies uh that needed to report and that's the stop the clock procedure uh indeed it was already mentioned 80% of companies would be removed from mandatory reporting uh only covering companies that have more than a thousand employees so it's significantly reducing the scope of the reporting uh also in terms of uh lessening let's say the load for for companies uh the ESRS so again
• 17:30 - 18:00 the European sustainability reporting standards data points will be reduced there's a lot of narrative so text to be included in a report and the proposal now is to really prioritize uh quantitive data points over narrative um the removal of sector specific standards which was still something to to be developed um and of or sector specific standards for instance in agriculture or food more guidance for companies uh but
• 18:00 - 18:30 that was uh um yeah let's say not included in this scope uh and no future reasonable assurance required uh there is now in the proposal limited assurance uh so the accountant will check uh yeah with limited assurance the um the non-financial statements and re reasonable assurance is now out of scope let's say um Then last but not least VSME so it's a voluntary reporting standards um it's um yeah it is
• 18:30 - 19:00 recommended for companies that uh that are no longer meeting uh CSRD thresholds and and need to report also because it then can function as a value chain cap so it helps companies in the value chain to say hey these are my material topics these are topics that really matter to me on which I am reporting meaning um the other data points that are in CSRD are are not relevant for me as an operator so it's it's meaningful in that sense and it's also meaningful to
• 19:00 - 19:30 reports um on on sustainability of course so that's a brief overview and if I look then at the specifics which is the next slide always good to know all these waves here you actually see the the waves themselves so first as said the NFRD companies the previous legislation uh which are now currently reporting a lot of reports coming out Denmark is actually leading the pack in terms of uh uh countries reporting but there's many
• 19:30 - 20:00 other uh yeah larger companies of course following um then the second wave companies they actually need to report over this year in 2026 and again the proposal is to then report in 2028 over financial year 2027 so yeah giving these companies more time to prepare and also again limiting the scope of companies by about 80% uh then listedmemes which is not uh yeah big in all markets let's say
• 20:00 - 20:30 but they also uh uh uh yeah have the same uh phase later requirements let's say one year later than the wave 2 companies so that's a brief summary here then you also have the non-EU companies so that's companies with a significant operational interest in in Europe that need to report and they also will be uh reporting a bit later so this is the uh scope and timeline of the CSRD as it is now proposed and then we
• 20:30 - 21:00 have a another slide which provides more detail on the CS D so again this is the corporate um due diligence directive um so in terms of timing uh it is uh the proposal is to delay it with one year the implementation um and uh the good news is actually for companies that guidance will be out sooner than than later so one year earlier which is actually quite nice if you're preparing as a company of course um now the scope
• 21:00 - 21:30 uh or of the due diligence duty has been narrowed quite a bit uh because now uh uh um the scope really is on tier one so meaning the first yeah chain let's say of your supplier and these suppliers need to be have more than 500 employees so that's a significant reduction in itself uh also um um the risk assessment which is is really worth mentioning uh
• 21:30 - 22:00 so this is should be repeated every five years in all honesty it's really good to actually do that every year and on a regular basis because otherwise you don't know what to uh what's happening in your value chain but uh but still uh you you need to really structurally review this every five years on this proposal um uh actually for the climate transition plan which you also know from CSRD so the reporting requirements is actually very much aligned with that so
• 22:00 - 22:30 uh the obligation to put into effect would be uh yeah stricken from uh from the proposal and also looking at fines and liability uh so it's national civil liability over harmonized EU conditions and there would not be any penalties in this proposal so that's CS D so that's um a bit technical but what does it mean that's also nice to to look at which is the next uh slide um Diamond I think we will have to due to the time constraints
• 22:30 - 23:00 uh perhaps we'll give the floor to the to our commission representatives uh oh sorry go ahead go ahead my apologies i I'll keep it short yeah so that's the next slide uh and you can skip to this slide because I think it's nice uh so the companies we work for uh they're convinced that it's important to keep driving sustainability forward so in other words less mandatory
• 23:00 - 23:30 reporting does not mean that ESG so environment social governance or sustainability is less important it's key to measure impact of course because otherwise if you don't measure impact you don't know where you are at um CRD remains a very relevant guidance framework for for companies uh that have invested into it so yeah use it as such and u sustainability reporting has been around for uh for a long long time global reporting initiative other initiatives that are meaningful uh so
• 23:30 - 24:00 yeah please uh keep doing that and it's meaningful next to of course the the companies that are required to report on the CSD so that's my contribution and thanks for the extra minutes okay thank you very much um we'll now have the Martin Berlin uh from DG FSMA uh please Martin the floor is yours thank you i have given some slides as well i don't know if you can uh show
• 24:00 - 24:30 them on the screen no yes they are thanks so I will um building on what was just said I will zoom in a little bit more on uh the CSRD and also say a couple of words on uh on the taxonomy so the the package that we put forward uh aims at uh drastically uh simplifying the rules for businesses uh
• 24:30 - 25:00 but of course we also want to uh uh make sure that uh the EU can still meet its environmental objectives so that's the the essence of the package and and we hope that we we we were able to uh to find that necessary uh balance let's uh let's move to the first uh slide postponement can you move to the next slide thanks uh so the omnibus uh package uh proposes postponing by two
• 25:00 - 25:30 years the entry into application of the reporting requirements for companies that are not reporting this year so as was said uh the so-called waved two and wave three companies so not the biggest ones they will have to report respectively in 2028 for the financial year 2027 and in 2029 for the financial year 2028
• 25:30 - 26:00 uh but many of these companies actually actually will be relieved from sustainability reporting obligations if the co- legislators agree with the commission proposal the next slide so I come to uh to the scope uh so the proposal will exclude all companies with up to 1,000 employees indeed from the scope of the CSRD and this means that uh uh as was
• 26:00 - 26:30 said the number of companies in scope will be reduced by about 80% um uh but it is important to stress here that descoping 80% of companies uh from the CSRD does not mean that this 80% of companies will no longer report uh only they will not have the obligation to report uh but many companies will still report voluntarily uh as they fall within the value chains of larger companies and financial
• 26:30 - 27:00 institutions or because uh they want to attract sustainable finance and and therefore they will see merit uh in nevertheless uh reporting next slide please so importantly uh uh we need to uh shield uh smaller companies uh from the implications of the reporting that has to be done by larger companies this
• 27:00 - 27:30 is what the value chain cap is about so for companies which will not be in the scope of the CSRD anymore so up to 10,000 employees the commission will adopt uh by delegated act a voluntary reporting standard based uh on the standard formemes the VME standard that has been developed by Ephra uh that standard in a way will act as a
• 27:30 - 28:00 shield by limiting the information that very large companies or banks that fall into the scope of CSRD can request from companies in their value chains uh so this again should protect company companies outside the scope of the CSRD from excessive sustainability information requests that they might get when they are in this uh value
• 28:00 - 28:30 chain and also regarding the value chain cap the omnibus proposal includes a provision which states that auditors and assurance providers must respect the value chain cap and that the reporting company is deemed uh to comply with CSRD when it respects the value chain next slide please an important element and also a very costly uh element potentially for
• 28:30 - 29:00 companies has to do with audit and insure assurance here the proposal is to remove the possibility for the commission uh to uh propose moving from a limited assurance requirement to a reasonable assurance requirement the reasonable assurance requirement is a lot more expensive for companies and therefore we would uh significantly uh decrease audit
• 29:00 - 29:30 uh costs next slide now on uh on the content on the substance of the standards themselves um the commission will revise the delegated act establishing the ESRS with the aim of substantially reducing uh the number of data points clarifying provisions deemed unclear and
• 29:30 - 30:00 improving consistency with other pieces of legislation and also reducing uh the number of data points and we have asked Ephra to already start working on that also uh the uh proposal that we put forward deletes the empowerment for the commission to adopt sector specific standards which would have come on top of the sector agnostic standard and this will uh of course uh further reduce data
• 30:00 - 30:30 points and also uh risks of you know complications and overlaps coming from two uh sets of uh standards uh finally two words on um uh the um taxonomy uh reporting here as you know um uh right
• 30:30 - 31:00 now um all companies in the CSRD scope uh must also report uh taxonomy indicators under article 8 of the taxonomy regulation what we have proposed is that reporting on uh taxonomy alignment would become voluntary for large companies that are in the CSRD scope but that have a turnover uh below 450 million euros and
• 31:00 - 31:30 also uh as regards the taxonomy there is a stronger emphasis on uh transition finance with the introduction of uh an option to report partial taxonomy alignment so this is the essence of what we have proposed uh maybe two words and that's not uh in a slides on um the impacts that we have
• 31:30 - 32:00 estimated we think uh covering now the entire uh CSRD package we estimate that the total annual cost savings of the changes in the CSRD scope and also the future modifications to uh ESRS uh could be in the range of uh between€1 billion euros and 2.5 billion euros uh for reporting costs and between one one 6 uh billion
• 32:00 - 32:30 euros and 4.2 billion e when it comes to audit costs annually and there will also be savings of one-off costs uh to set up and implement the reporting and assurance processes which have been estimated to amount uh to uh something between 1.2 billion euros and 3.2 billion rupees so it is a uh surely uh quite a quite a significant alleviation
• 32:30 - 33:00 of costs for companies and especially I'll stop here thank you very much um we'll have now Alexandra Palinska from URIF who will tell us a bit more about the impact of the omnibus on the market thank you very much and uh hello everyone and it's a great pleasure to be here today and discussing this very important uh subject so um I represent URIV the European Sustainable Investment
• 33:00 - 33:30 Forum uh and we basically represent uh the voice of responsible and progressive investors across Europe i'll start maybe a bit provocatively omnibus one a simplification or as one of my actually um colleagues and and friends refer to as compification package well I think the objective of the omnibus one initiative is indeed to
• 33:30 - 34:00 make life for companies easier i think currently sorry for using the strong words but I think we are living a little bit through the cows you know everybody including our members and their members uh asking like okay what do we do in Spain actually we have not really fully transport CSRDS so we are still applying against you know non-financial reporting directives so what do we do you know so many companies even uh here you know a gentleman from Feder that will be speaking in a moment has also actually
• 34:00 - 34:30 been telling this story about actually their company already preparing and having invested in sustainability reporting and you know honestly this is you large investments we are talking about right because let's not really forget that actually the largest companies already actually gone through the first year of reporting which usually is the most costly one because the companies you know they have to do the first uh time materiality assessments set up all the processes you know prepare the IT systems so actually
• 34:30 - 35:00 the first year is always the most costly and now we are telling all of these companies well actually we are changing so Um I I think this is you know I would say a very difficult moment uh at the same time well me representing here again the investor's voice what the investors are concerned about for the last 10 years investors including very mainstream ones and really not even the ones interested in sustainability have been calling for
• 35:00 - 35:30 improved comparable and reliable sustainability related disclosures and well this is actually why corporate sustainability reporting directive has been adopted and because you know if we think about it the predecessor of CSRD so non-financial reporting directive that has already required 10 years ago companies actually to um companies with
• 35:30 - 36:00 more than 500 employees so they're actually the scope is actually you know the threshold is much lower than now actually the proposed thousand employees threshold um well already required actually companies to uh report sustainability well at the time called non-financial information and have been you know already doing it for a while but because there there wasn't requirement actually to do these disclosures against one standard that well one standard it it still did not resolve the matter of the
• 36:00 - 36:30 fact that actually the information was not really truly comparable also actually investors needed more data also from the companies which are smaller than those with 500 employees so now I think it's it's it's a very particular moment because you know sadly we're actually backtracking on on the progress we have done without really even having allowed this new law to actually bed in which my recollection is has always been really the practice you know to wait at
• 36:30 - 37:00 least two three years uh you know since the law applies and and then reassess so uh right now in that indeed I think investors are also concerned like okay on one hand side I I think it's very important that drug report has been mentioned right with the uh investment gap of around 800 billion annually in order to meet actually the objectives of u industrial decarbonization and competitiveness but the issue is that indeed investors are supposed to also help close this gap
• 37:00 - 37:30 but how can they do so if they don't have the data on top of that now we actually even a moment ago just heard that actually w with with the you know uh value chain cup they might be even prohibited from asking actually companies the data which honestly I personally find you know a little bit shocking and I think it dangerously starts to sound like you know the situation actually in US where even the investors that actually do wish
• 37:30 - 38:00 to consider ESG risks and other matters and embedded in the investments are actually prevented from doing so which is actually impinging on the freedom of investment so I I I think you know we are living in very I would say um critical moments and very I think unpreented situation whereby I think everybody has very good intentions uh but I'm afraid we might be actually going in the direction of throwing the baby out with the bath water and uh
• 38:00 - 38:30 indeed you know I I picked up I think um on um you know how my fellow speakers also referred to actually uh removing 80% of companies from the scope of this directive using very strong words which I would fully concur with you know I'm sorry removing 80% companies from the scope this is massive so you know I would say okay fine if we really want to strike the right balance why don't we actually compromise at the 500 that for instance non-financial reporting directive set already 10 years
• 38:30 - 39:00 ago and um so I I think and you know of course we can always hope that some companies will still be reporting on a voluntary basis but I can also tell you that from the one-to-one discussions we understand unfortunately that's not going to happen maybe some companies that have always been the front runners might be doing so but unfortunately I think a big number of companies have been admitting in those one-to-one discussions that if they're not going to
• 39:00 - 39:30 be actually obliged they're not going to do so um so uh on top of that for instance here the voluntary theme standard and uh I can tell you I have been actually uh following uh the development of this standard quite closely because um until a year ago I was also sitting on the FRA sustainability reporting board um and uh and and basically you know like the VSme standard was really created with the aim to serve as a standard for corner shop
• 39:30 - 40:00 companies not with for companies with up to thousand employees so I think you know if we really want to go in in that direction what we should be rather uh looking it at is maybe either keeping or reviving and repurposing the listed theme standard which at least has a structure which is much closer to the main standard hence would also ensure much better compilerability for investors uh and uh and and also basically you know is more meaningful
• 40:00 - 40:30 because actually the very thememe standard is just kind of you know a a kind of not not very long list actually of um you know I would say a couple of data points uh missing you know a lot of very important ones uh maybe just one more point also here on the CSRD so as you have all seen uh the requirement uh I would say here the idea to develop sectoral standards has been removed which okay fine fair enough but I think what is really needed is guidance for
• 40:30 - 41:00 the sectoral disclosures because what I think very often is forgotten about actually the sectoral standards that were supposed to be helpful for the companies from different sectors to help them identify which of the disclosures are most material to them and I can also tell you that you know Even some of the very big players uh from the financial markets that are maybe not always seen you know as the most progressive one they have been also telling me like look actually we were supportive of the sectoral standards maybe you know a kind
• 41:00 - 41:30 of a shorter you know kind of a sector agnostic standard but then indeed sectoral disclosures you know to to make it clear which of those standards actually have to be uh disclosed and maybe just very quickly uh on the corporate sustainability due diligence directive in particular on transition plans uh and climate targets i mean this is really one of the most important uh I would say here requirements uh and an essential one really for EU to achieve its objective
• 41:30 - 42:00 of industrial carbon decarbonization and um uh basically I I think you know it is very questionable why um the requirement to implement the targets has been removed i mean well we're already thankful that at least I would say the requirement to set the targets is still there uh which is really essential but you know otherwise okay what's the point of setting the target if you don't implement it right so it's it's just basically opening the door to um you know window dressing and
• 42:00 - 42:30 greenwashing which the entire e sustainable finance agenda has been actually trying you know to prevent and uh yeah finally also on the corporate uh sustainability due diligence directive what is I think very particular is that this directive has been really developed and based on the international standards already very well recognized and known by many companies so the OECD uh standards for multinational enterprises and also uh UN
• 42:30 - 43:00 uh global guiding princ principles and um now what what we actually failed to understand if really the objective is the simplification why suddenly actually the the changes make it actually this directive depart from that and also remove the riskbased approach which is actually the main mechanism to ensure that actually this is not a tickbox exercise and that actually it is feasible and implementable and not overly difficult one minute thank you
• 43:00 - 43:30 thank you great thank you so much um also for keeping it uh in in our time framework um we um I would propose that we go directly to the second panel so please um um a kind uh request to our speakers bear with us um for the Q&A session at the very end of this event um and we'll now go to the panel focusing
• 43:30 - 44:00 on the business and civil society perspectives on the uh omnibus initiative uh we'll have Marian Lupon uh senior policy officer um at the European Coalition for Corporate Justice uh we'll have Veronique Williams secretary general atme United um Patine Hen um director of environment and sustainability at Food Drink Europe um Aldo Cristiano head of institutional
• 44:00 - 44:30 affairs and sustainability at Ferrero Germany and Ila Brockmire um head of public policy EU and international metro I would say um please Marion if you could um the floor is yours thank you thanks a lot uh for having me here and allow me to represent
• 44:30 - 45:00 civil society at this event uh I will try to be brief i will address two concerns two main concerns from civil society on the content of the omnibus specifically as it relates to the due diligence directive and then make some more general comments um the first and main criticism so to say um of the proposal uh would be that the proposed changes to the corporate due diligence
• 45:00 - 45:30 value chain uh would limit obligations to primarily direct suppliers of company the so-called tier one while we understand that this may appear to simplify compliance at first glance we also think that there are massive issues in terms of implementation uh we know that this omnibus legislation when it comes to the CSVD was heavily inspired by an existing German law uh that has been into effect so for that specific that we are able to have
• 45:30 - 46:00 feedback from industry and companies that have had to implement it and it has been clear in the one two years since it has gone into effect that there is an issue with flooding direct suppliers with questionnaires and paperwork and request of compliance specifically because we know for a fact that the most severe and the most concrete risks do not lie on tier one of the value chain they lie much lower we strongly believe
• 46:00 - 46:30 that this proposed approach would lead to an overburdening of what can be considered lower risk suppliers many of which uh also happen to be based in European countries so are would be subject to EU social and environmental standards already uh so as in no way do we see that this decreases bureaucracy this decreases compliance burden we just think that it forces company to focus it on the wrong place instead of giving
• 46:30 - 47:00 them the flexibility that they need to assess where and prioritize crucially where my risk for my supply chain lie um there is the issue of liability which is a massive issue from the perspective of civil society the removal of a harmonized EU clause uh does nothing to simplify life for companies will hamper victims in their request and their need to access justice after a harm has been
• 47:00 - 47:30 done because they will have to navigate 27 different legal system that would impose 27 different conditions under which you can or cannot be liable and crucially these national existing systems have proven recurrently insufficient to guarantee victims of corporate harm access to justice which is internationally recognized human rights and an obligation for member states to provide in general uh on the changes that are uh presented by this
• 47:30 - 48:00 initiative that are often motivated with the need to reduce burden onmemes and protect Europeanmes and their competive iveness uh we would like to remark again that the current CSDDD as it exists provides ample measures in support including but not limited to financial support formemes so that they are not overburdened with the cost of compliance
• 48:00 - 48:30 uh I but I very strongly want to make the point that this is not just a theoretical benefit something that is in the letter of the law i mentioned before there are problems that are becoming evident in the application of the German legislation and we have a group of over 15 Germanmemes that has issued recently a call to the German government to implement these protections that are in the current version of the CSDDD as a
• 48:30 - 49:00 way to redress and remedy what is currently going wrong with the implementation of the German legislation specifically when it comes to assistance and protection formemes where we do see issues in in potential and we believe there is a need to act is on the prohibition for large companies in scope to pass down their obligations of compliance ontomemes and onto lower suppliers that is something
• 49:00 - 49:30 that happens it is something that needs to be addressed and we call strongly on the commission but also the co-leis to uh come out with an agreement soon so that this practice of dumping down obligation can be legally prohibited thus protectingmemes and posing the charge of compliance on large and wealthy multinational that h very much have the money to undertake these processes in general and on the theme
• 49:30 - 50:00 burden argu argument i think it bears repeating thatmemes themselves have come out in the past in support of CSDD for their own interest we have the example of the confederatanato an Italian member of United who said at the moment of the conclusion of the negotiation that legislation like the CSD is crucial in ensuring a level playing field with other actors that may not be quite so responsible or frontr running in terms
• 50:00 - 50:30 of sustainability legislation we have another example that is very relevant to this particular forum the organizo for the non-Italian speaking people in this room the tomato sauce project where producers of tomatoes in the Italian agricultural industry have many times made the point on how global competition and uh just yeah an open market puts them in direct competition
• 50:30 - 51:00 with actors that have no care about environmental or social standards triggering a race to the bottom now by diluting these obligations in social and environmental standard will do nothing to improve their competitiveness it will bring them back to the same level of actors who are already way ahead of them in terms of production and competitiveness csddd is a crucial instrument to ensure
• 51:00 - 51:30 a level playing field where first movers where ambition ambitious actors that have done work and there is work being done on fair labor practices fair wages safe working conditions safe environmental standards it is crucial so that those first mover those ambitious movers are not punished but rather rewarded as first movers i will conclude in saying there is one key message that
• 51:30 - 52:00 I would like you to take from civil society today and it is that competitiveness and sustainability simply cannot be seen as opposing force they cannot be seen as obstacles to one another because the only true form of competitiveness is one that is anchored in long-term sustainability the accountability that we are looking for for victims for communities for our environment is an accountability that sees the harm being done now and brings
• 52:00 - 52:30 acceptable answers to ensure yes competitiveness and a strong economy but a real remediation of those harms and crucially a long-term prevention that in 20 years the business as usual of now is a longforgotten practice thank you thank you very much Marian um let's um um now move to Veronique uh please the
• 52:30 - 53:00 floor is yours i thought there was some other speaker still ahead of me if I understood the order well oh okay good i don't know whether I still have to say something because my neighbor actually said everything formemes although I don't agree on everything um so excuse me I am very prepared um I would like to start by saying that
• 53:00 - 53:30 we wouldn't have needed the omnibus if the think small first approach would have been applied from the start and we'll continue advocating for this throughout all legislation that is being developed in Europe on all levels and on all topics um because if you start working for the majority of companies in Europe the 24.2 two micro companies with less than 10 employees instead of drafting
• 53:30 - 54:00 legislation for the 43,420 large companies active in Europe then we wouldn't have had this debacle so that is my first point and I think in that in that sense I come very well prepared um what does that mean that means that you develop legislation based on the capacity and the characteristics of the smallest ones and You then add layers depending on requirements that
• 54:00 - 54:30 are needed because of larger companies having uh a larger impact being uh bigger in in size and impact on the society and in that way you build a ladder a development path for companies rather than starting with the top of the mountain and expecting everybody to be able to jump on it immediately so that's our first point and in that way we are also very grateful to the commission that they have taken on board the concerns of the small companies who were neither in scope of the CSL D nor of the
• 54:30 - 55:00 CSRD but in any case were demanded by the value chains to comply with those uh pieces of legislation so we thank the commission for now uh repairing the unintended uh impacts that uh have been created by the two uh legislations um I've already mentioned they have been impacted through the trickle down effect in the supply chain uh and that was another element that had to be corrected because in the impact assessments that
• 55:00 - 55:30 was not taken into account that's another element that we're advocating for in general making sure that even though you you do not putmemes in the scope that you take into account that indirectly they might might be affected and if you don't take them along in the impact assessment you also immediately omit to develop measures for support and so on so that's the second element in in advance um third element in advance and
• 55:30 - 56:00 that's my last one and then I go a bit more in detail third element is whatever time of postponement we don't care what is crucial for us is that all the tools are ready to allow SMBs to prepare for compliance well in advance so not one month not three months not six months but at least one year for sure preparing giving them the time to prepare for the new legislation as has been said already a few times there's a lot of one-off
• 56:00 - 56:30 costs setting up a system and that requires a small company owner with two three four employees who is working with their staff throughout the day to provide us with quality products and services and in the evening they start looking at what is the business development that I have to prepare for what are the new rules that are coming my way how am I going to comply with this that all comes to that one person dealing with everything and that one person need tools and it's time to to start implementing those tools in the
• 56:30 - 57:00 company so whether it's now one or two or three or five years the tools have to be ready and as of then we start counting on the CSRD we are very happy that now the VSME has been put in place as the value chain cap for information it's already been mentioned we've been putting a lot of work and theme has been SM United has been contributing since 2020 to the development is it already a good one no we still see room for
• 57:00 - 57:30 improvement is it feasible maybe if we develop the right tools and if we now start working with stakeholders with our theme organizations on the ground to develop the tools to develop the training to develop the support for thosememes for those entrepreneurs to really start preparing uh for the implementation linked to that we also ask the commission to now endorse the VSME as soon as possible we understand that you've decided to postpone the
• 57:30 - 58:00 public consultation as long as the the current uh process legislative process is going on ourmemes now need certainty on where they have to navigate to so that's I think a very important element secondly uh the exclusion of the midcaps um I've already said it exemptions for us is not simplification exemptions for us is not a solution because you still have the trickle down effect so you're you're correcting that now with with
• 58:00 - 58:30 nevertheless for the future please think small first act accordingly and start building up um the limit to the possibility to ask for assurance is a very important element for us as well um we do not want ourmemes to be confronted with additional costs of audits for something that they are legally not even required to provide so on that perspective formemes we really want to have the
• 58:30 - 59:00 insurance that assurance will not be needed um it's already provided for in certain transpositions in national law so I think that could be also a source of inspiration uh towards the future looking at the CSL D again are out of scope nevertheless we've heard many uh small companies already who were confronted and you've you've mentioned it already with large companies putting in place sustainability contract that
• 59:00 - 59:30 they had to to sign to comply with uh with certain uh elements this is not feasible what we do support is more harmonization and also limiting to tier i think there we completely disagree i agree with your example on uh the flooding of the companies in uh in the tier one but I think it's also flooding tier two to tier three our basic remark is in Europe we have a legislative framework in
• 59:30 - 60:00 place when you comply with that legislative framework you shouldn't be doing any reporting i now have examples of entrepreneurs who had to say yes I do not do child labor yes I do not do slavery it's a bit like the the ESTA going to the US no I am not a terrorist for those entrepreneurs it's like they're they're being laughed at in their face because of course they are not doing slavery of course they are not doing child labor because if they would be doing that according to European laws
• 60:00 - 60:30 they would be in jail so replacing um market authorities ensuring of compliance by making companies comply with each other is not the right way forward to for us um tier one would ensure that the direct contact that you ensure that there are sustainable practices and then you trickle down as well so we would like to see at it from a positive uh angle on taxonomy uh I
• 60:30 - 61:00 would like to highlight the simplified approach that has been agreed in the sustainable fence platform which um leaves which gives a lot of advantages and opportunities now again to build up uh for a small company towards uh sustainable finance uh criteria and on uh sebum uh we are happy that uh there is uh a huge simplification so that's first reaction we are still consulting our members more in detail but I think also going into the technical details
• 61:00 - 61:30 here would lead us too far thank you thank you very much and uh Katherine now the floor is yours thank you very much and good afternoon everybody yes um thank you for the invitation to represent food drink Europe here to the table i would like to start with giving you a little bit of context so what are we talking about in the food and drink industry the food and drink um is Europe's largest manufacturing industry just a little reminder on that also the EU drink industry is the largest exporter on food
• 61:30 - 62:00 and drinks worldwide and um well maybe some very few numbers here um the food and drink industry in Europe employs 4.7 million people generates a turnover of 1.2 trillion euro and uh around 3/4 of the US of the EU's food and drink products are actually delivered to the single within the single market while again as I said before the world's largest uh exporter on food and drink so what's
• 62:00 - 62:30 specific also to our sector we have been striving for sustainable and resilient food systems already for quite a while before the green deal even came up um and we are one of the first sectors as the supply chain is very much linked to farming projects products and agriculture one of the first to also suffer from climate impact and environmental impacts so that's why there's a high interest in keeping us all on the right journey here um another specific um thing about our sector um
• 62:30 - 63:00 the value chain is quite diverse so it starts with the farmers goes to the food and drink industry which again comprise small and mediumsized enterprises microenterprises and large companies both EU based and US based uh then goes over to the retailers and finally to the consumer so it's quite a complex value chain before the omnibus came out so we have been following this with high interest in looking at particular what does it mean for the food and drink industry we came up um pre-launch let's say with a few key principles but I will just maybe in a nutshell so we basically
• 63:00 - 63:30 said that we support fully support the objectives of the CSRD the CSD and the EOXonomy um and we are committed really to um to use these tools to help us go this transition towards sustainable and resilient food systems so to to go the next steps on this to doing so in a business friendly way which we hope the omnibus will be bringing and also that it should be a smart and targeted simplification not a compl as we heard here before but a simplification process
• 63:30 - 64:00 that really targets what needs to be simplified for industry so now post omnibus um we basically as I said our membership is quite diverse so we looked in terms of what are the risks and the opportunities that we see from the different perspectives as we really need to outweigh and balance them and consider them hopefully in the design process of this omnibus proposal so overall risks I quickly run through ma major five risks that we see um it depends on how it will be designed it
• 64:00 - 64:30 could be geopodizing the ambition level of the legislations mentioned so on the sustainability transition of companies um it it depends really on how this will be done so that there is still a meaningful measurement and monitoring possible for companies um second point is how to keep track on the supply chain so how to keep track on risks and decarbonization along the supply chain if the data provisions are limited to
• 64:30 - 65:00 only large companies that are in scope uh of this new legislation so again it needs to be discussed how that will be taken care of um and there's a a critical link also then both formemes and for the largest um on how this will be dealt with both with for CSRD and CS D um so CS D you only have tier one reporting uh and both of them you have only the larger companies with the mandatory reporting how will that play out in practice so will that really be
• 65:00 - 65:30 an advantage then for the smaller ones will we get all necessary data i think there need to be some discussion and maybe an impact assessment on how that could be realized in practice to see that it's working so that's the goal I guess um a third risk is the uncertainty and unpredictability of the changing as this is an um precedent this the first omnibus so does that mean that existing legislation will be changed what does that mean for investment decisions we also had that before there is some uncertainty so really certainty is
• 65:30 - 66:00 important and uh for companies that already invested in compliance measures rowing back now and costs already invested this is also um a problem that needs to be addressed in some way opportunity now so simplification and reducing administrative burden very welcome across the board i think there's a high demand for that um then for companies that are not yet on this journey and are part of wave two or three or not yet prepared there's also the chance for the process to be more
• 66:00 - 66:30 streamlined and to be more targeted so less of an effort um then there are opportunities for companies under the threshold to not be obliged to report but to do so with this volunt voluntary report if they want to and not be asked further information so could be an advantage for these companies um there is a big opportunity that we see in the alignment between the different legislations because there was a lack of alignment between CSRD CSD specifically in terms of scope of companies in terms
• 66:30 - 67:00 of uh terms used like minimum wage and another term in another so adaptation of the timelines and of the scopes very welcome to make it easier altogether and then the delay stop the clock uh welcome certainly by those not yet in the race and also in terms of getting clarity and certainty so that links then to our key demands um I limit it to three the three key demands that we have we would like to
• 67:00 - 67:30 urge the European lawmakers to provide legal clarity as soon as possible and yeah you hear that a lot but it's also really super important a clear timeline and both for the EU and also the member state implementation because in some member states there is already legislation in place so there also needs to be clarity on how will that be adapted in this process um our sector sees the urgency to continue the actions on climate change and we remain fully committed to that in our broader sustainability journey so this should be still be the objective we hope and um we
• 67:30 - 68:00 really want to be sitting at the table so involvement of stakeholders in how this design is being made to address these issues that I raised before i only raised a few there more so to really discuss that it is designed in a way that makes it simpler and easier and keeps us on our journey thank you thank you very much um now um we'll I'll give the floor to Aldo please so thank you so much and also delighted to be
• 68:00 - 68:30 here and grateful to the organizer have for having me here and let's uh speak about the business perspective or better from a confectionary company perspective which is operating in a responsible way when it comes to sourcing and sustainable supply chain now the omnibus proposal has four pieces of legislation and uh two are for us of immediate uh operational impact uh and those two are
• 68:30 - 69:00 the reporting directive and the due diligence um on the first one uh my neighbor just said it um the reporting obligation for a private company like ours uh is pretty new and therefore we have been putting in substantial investment to comply with but this is a different type of impact when it comes to the omnibus overall for us as a sustainable and responsible
• 69:00 - 69:30 supply chain actor uh for us it's more critical the due diligence part the due diligence part and the way we are doing business when it comes to palm oil or cocoa which is obviously a key ingredient in our um supply chain is to proactively manage human rights and environmental issues in supply chains and how do we do this uh I just want to give you a short and a quick overview is
• 69:30 - 70:00 the starting point are our suppliers and in our company we have 20,000 and more suppliers which you need to tackle and in order to ensure that you have a responsible sourcing commitment you need obviously first of all to look in such a um supplier code approach what are the human rights and social practices what are the environmental protection which we need to u uh guarantee and how do we
• 70:00 - 70:30 get fair and sustainable supply chains in order to mitigate potential issues because they are there we know this we are operating in areas which are poor countries and we need obviously to tackle these issues um and to give you just a very quick insight is if you have thousands of suppliers you need to classify them ideally you classify them in high medium
• 70:30 - 71:00 lowrisk suppliers and therefore you need obviously uh to see the higher the risk is the more you need to go deep into the supply chain so we cannot stop at tier one when we see that suppliers are in areas which are of high risk so that's why I want to make the point on tier one and I come later um to the omnibus proposal um to stress this point a bit
• 71:00 - 71:30 deeper in all of this when you start to classify suppliers you do a risk analyszis right you need to understand whether by spending or by critical areas where are the risk and you need if you have a supplier code make sure that your suppliers are in compliance right in In order to do this you do either assessments you have service provider like Echovadis for instance or you do your own
• 71:30 - 72:00 audits the deeper you go through the supply chain the higher the risk is the deeper you need to have and in the end you need to have an approach which is a we call it a mitigation program and the mitigation program means that you're not going to leave the small suppliers or the small uh tier 2 three four five whatever the depth is of a supply chain alone you need to work with them together so it's not just an exercise of taking the supplier code and signing it
• 72:00 - 72:30 as we have heard it today it is more a collaborative activity together with your supply chain actors because we need to ensure that deep down the road we get a supply chain which is sustainable right um and to give you a bit of experience is that we do around 100 to 200 audits in our supply chain down down down on the ground in order to understand how
• 72:30 - 73:00 much compliance or how much the mitigation programs are working and having impact and the logic goal of this is to have a system of control or we call it also an effortdriven approach rather to have call it final product approach or an end resultdriven approach because importing all of this and this is very difficult we have a lot of experience in how to
• 73:00 - 73:30 tackle really supply chains which are at high risk you need to have a system of continuous improvement that is crucial you cannot switch on switch off by a legislation that suddenly you get everything done okay that is really a learning which we have gone through the past years and uh that's why uh we have seen that that approach has brought over the years higher compliance better ratings of our suppliers tier 2 three
• 73:30 - 74:00 four so that that shows there is a model of a riskbased approach which is part of the business is integrated in the business and you need to do it and you cannot stop you need to have that kind of approach in order to go through but let me come quickly back of the critical elements of the proposal we've been hearing tier one we've been hearing civil liability and from my
• 74:00 - 74:30 perspective as I explained it for us it's naturally that we go beyond tier one because based on the risk assessment you need to go through you cannot your eyes and say there's a piece of paper I've signed it you need to go through if you are responsible business and when it goes beyond we can't do it alone our suppliers subsup supplier sub of suppliers we need to have clarity and
• 74:30 - 75:00 we've heard the word a few times today what it means to engage smaller companies right at the moment there are some ideas when smaller companies should or should not there are ideas of exemption we've been hearing exemption today a few times but rather than an exemption it's better to have a tool for them to come up and to help to make the supply chain more
• 75:00 - 75:30 compliant to what the expectations are so we've heard it before from one of the speakers that rather than exemption it's better to have a tool for them and to help them on the civil liability i think it is extremely important that we have credible systems right credible systems when it comes to civilizability but in a sense that we
• 75:30 - 76:00 have a certain balance and what do I mean by a certain balance on one side we need to have a credibility a credible system when it comes to liability on the other side obviously we don't need to go into a kind of litigation environment we cannot always come up with litigation one day after the other we need to have a nice balance between the two of them right and that is something which we see in a
• 76:00 - 76:30 pragmatic harmonization that we can achieve it right what is also not in favor of businesses throughout Europe is to have different liability systems in different countries if you have Germany with the alkais or you have France or you have other countries we need to have a harmonized system which is helpful and gives again
• 76:30 - 77:00 a certain assurance a certain a certain way of planning and having uh for a company obviously um something which is um clear at the end clarity is something which we need and therefore discussion about guidelines the discussion about it's it's an acronym which I always get difficult to spell it VME where you have where you need to have and I think work being done and and
• 77:00 - 77:30 will be gone further when is the moment of clarity where smaller companies need whether they are lower than 1,000 lower than 500 but need to come up and to collaborate collaborate in a way that uh we can mitigate the risk and we can get rid of the risk and we can have remediation in order to have again it's all about a responsible long-term sustainable supply chain right and that's why it's pretty
• 77:30 - 78:00 important at the end of the day and I want to close with the thinking of having a pragmatic approach right a pragmatic and feasible approach which allows was at the end of the day the so-called spirit of the UN um guiding principle to comply with the spirit right and the spirit is to improve step by step ideally the steps should be
• 78:00 - 78:30 quicker than uh some might think in order to achieve really a fair and a sustainable supply chain and that's important that we get a legislation where we are able to commit to to have a level playing field and to make the turnaround of supply chain which today are not acceptable perfect thank you very much um and now we move to the very last speaker um in our p panel please the floor is yours
• 78:30 - 79:00 hi um so my name is Ila as already said um I work for Metro i also prepared a presentation i hope it can be shared um and I just wanted to um give a very brief overview you can go to the next slide please um of Metro just so you understand also the dimensions of um our company and
• 79:00 - 79:30 um when it comes to the reductions in scope that we have heard about um we are basically not uh not really impacted because we are such a large company so um what is Metro metro is an international food wholesale company and um our customers uh are mainly in the hotel uh restaurant and catering industry so uh not here in Belgium but uh in a lot of other European countries in 16 overall if you go to a restaurant
• 79:30 - 80:00 there's a high chance that you might be I don't know drinking coffee with uh Rioa Sugar for example that's one of our own brands and um we are um as I said not only present in 16 EU countries but um overall in over 30 countries worldwide and um we can go to the next slide please and the next one as well again because I think we are a bit short on time so just
• 80:00 - 80:30 um exactly um a brief very brief overview of our sustainability strategy because of course at Metro also sustainability reporting and sustainability management didn't start with um the legislation um that we have uh now seen coming from Brussels but we had our strategy already before and here you see the current three main pillars um the first one is climate and carbon the second one is ethics and trust And the third one is diversity equity and
• 80:30 - 81:00 inclusion i think most of the people here are expert on these topics so I don't have to explain that in detail but I just wanted to uh to give this um as a kind of introduction before I dive into uh the actual topic so now to the next slide um essentially we um welcome the proposals from the omnibus proposal however um as I already said we are in all of the
• 81:00 - 81:30 three uh pieces of legislation that you see here not really impacted by the uh reduction in scope but we are still in favor because uh we see good improvements on content suggested that we hope uh will also be followed through and um the first one is um considering the corporate sustainability reporting directive we are um really welcoming the plans to simplify uh the data collection
• 81:30 - 82:00 then also the plans to stay away from sector specific standards and also um the plans to um stick to limited assurance and just to explain why um data complexity I singled out one aspect of the CSRD which is um difficult for us or the most challenging for us to implement which is the fact that there is just a really big amount of data to be collected um potentially over a thousand data points um I think right now we are at um about 550 data points
• 82:00 - 82:30 and the issue that we see is that it's um a really detailed level of granularity which um is very prescriptive and it's very difficult to adapt it to your own business operations so to give an example Metro is um a trading company um not a retailer but a wholesaler so um comparison to Ferro um we um also have to disclose for example when it comes to manufacturing and production processes
• 82:30 - 83:00 but we actually don't own them so for us it's very hard to uh to say uh to provide data on let's say the energy mix or u measures in the value chain or whatever when it comes to um to our uh to the products that we sell in our stores when we are not a producer and um also the level of detail when it comes to um uh to the data points that we have to collect to give you an example for example when it comes to the energy mix
• 83:00 - 83:30 we have to provide information on uh emission for example on two different levels um when it comes to uh emissions for example in Germany but we have to not only provide uh data on the emission um that is uh calculated on the market but we also have to uh give it very specifically for uh for the location so basically we have to report double on the energy mix so just to uh to give an
• 83:30 - 84:00 idea of why we think it's a really valid point to look at the data complexity that's being reported on because there is a lot to be done in future to make uh yeah to reduce um just um the amount of data that has to be reported and then looking on uh at taxonomy um it's very similar to uh to CSRD happy to see efforts to reduce complexity and to simplify because um
• 84:00 - 84:30 it's just a matter of fact that the criteria are super complicated and I mentioned here one example we are investing in um energy inefficient cooling systems in um for an amount of 82 million euros uh which is quite a high amount of investment but we cannot uh declare it as taxonomy aligned and the the issue that we see with that is that the reporting criteria area are so strict that it really paints
• 84:30 - 85:00 a kind of distorted image of our sustainability um investment and our sustainability strategy and what the company's actually doing to become more sustainable and um yeah last but not least coming to the CS D um here uh we welcome the um planned uh delays in the implementation and also the content changes and what I want to highlight here again also um referring to what I said earlier
• 85:00 - 85:30 um the complexity in our value chain is really unique and we always like to say we we we think we shouldn't talk about value change chains but we should rather talk about a tree because the chain kind of um yeah says that everything is connected but for us um since we are traders we are buying and selling it's very difficult for us to um to really reach trickle down um to really reach the end of the value chain that we have
• 85:30 - 86:00 also talked about where um as we we all know um really the the most work needs to be done and at the same time it's also very difficult for our remediation measures for example to really um uh to reach the let's say worker on some kind of uh in some kind of production site and um for uh that person to uh to be able to uh to understand uh about Metro and to understand what his or her
• 86:00 - 86:30 possibilities are for remediation so we think it's very important that when looking at the CS D this um tier one discussion also takes into account that there are different kinds of business models and um since wholesale retail are not companies that are directly producing um we think it's very important that there you can also differentiate between tier one and uh and beyond and uh then uh I have one
• 86:30 - 87:00 more slide it so we think in this process that will take a a while and now we have four kind of guiding principles as we call them that we think should guide the the way forward one is we really argue for harmonization as much as possible across the EU as I said we are in 16 EU countries um yes it does matter if you have to implement one standard or 27 different standards that in our case
• 87:00 - 87:30 that's 16 um so uh connected to that we also really call for consistency because for example there are definitions that differ between the pieces of legislation um we think it's really important to uh to look that also EUDR for example is connected to uh to these pieces of legislation that we just talked about information sharing we've also discussed that today already and there is uh this proposal for a value cap um I can just
• 87:30 - 88:00 again say from our perspective since uh we really depend on others providing us with information for us it's very difficult to obtain the information if there is no obligation to disclose so um somehow we need to reach reach a compromise here where it's uh where it doesn't end in suppliers just having to sign pieces of paper but us needing the information also because we are not the ones that actually yeah uh produce the
• 88:00 - 88:30 um the product that we are selling and um last but not least um we just always also uh want to emphasize like what what is the uh the actual result that you are trying to achieve and should always be um yeah kept in mind if for example really on CSRD does reporting on uh so many nitty-gritty details really um improve um yeah the situation we are
• 88:30 - 89:00 we're not really sure we're not saying we're not against reporting but there is definitely um more efficiency to be created thank you thank you very much um at this point um I would like to open the floor uh for questions uh and I would also like to invite um MEPs if they do have any specific questions uh to our speakers uh please don't be shy
• 89:00 - 89:30 yes please thank you my name is UVski from the German Confectionary Association VDSI uh 90% of our members are SMMES this is why uh I first of all thank you for your very valuable input um I would have two remarks um the most um yeah important topics in this room today tier one and the value chain cap um and the question would be to Simon Alexandra Mariel and Aldo not all of you have to answer but I
• 89:30 - 90:00 would be interested in some of your opinions because um we only talked about one part of the draft I suppose so we do not have to stop uh by tier one and we don't have to stop with the value chain cap in the draft um it is um already mentioned that it is a riskbased approach so meaning when it comes to the limitation of the due diligence obligations to the direct business partners it already says uh except where plausible indications of risk in the
• 90:00 - 90:30 broader supply chain exist and if you check the recital number 21 it is explained what exactly is a possible in uh indication and there we have again the risk based approach like in the German law and there are some uh examples like if there are reports from media uh reports from NOS's if there are uh mentioning uh in in the grievance mechanism or other knowledge then you have to go deeper into the chain so it's already in the draft and the same is for
• 90:30 - 91:00 the value chain cap um it goes for the CSRD as well as for this uh triple D of course it's the starting point the VSME plus or the the delegated attribute will be elaborated by the EU commission um but um for example for the CSRD if there is no other possibilities for for uh companies who are um uh falling under the CSRD if there's no other possibility to get this information uh the the
• 91:00 - 91:30 supply uh supplier will be obliged to help to get this information and the same goes for the CSD D um if um there is um so there is this restriction to the value to the VSM me the value chain cap unless um necessary because the standard does not cover the relevant information the supplier or the big company needs so what's your opinion on that because I think there is already this riskbased approach um in the draft uh and I think it would be may be
• 91:30 - 92:00 helpful to just get more information about what exactly are possible information and what exactly um is the situation where you are um where you have the right to get more information than VSME thanks a lot a very extensive question um please um whoever would like to start Timman I see yeah I'm happy to start um basically echo echoing the room a little bit because it was said before so yeah um if you look at the UN guiding
• 92:00 - 92:30 principles the OCD uh framework um yeah it's not enough to stop at tier one that's that's apparent um and it's also good practice not to do that because actually a lot of companies if they see signals and signals being in indeed media reports NOS's uh local suppliers etc um they need to act right um so in that sense um uh well it's great that a risk based approach is is until in the draft but it does feel a little bit like
• 92:30 - 93:00 a step back to only stop at tier one um you know I've worked in the coffee industry for about 12 years the risks do not occur uh at tier one right and that has been echoed by my friends from the the cocoa value chain so yeah we need to be realistic there um so I think I think that's one part of the question I I'll floor to uh to others as well do you want first no I just want to also echo on the tier one and on the let's say on the challenging overall you see
• 93:00 - 93:30 on one side we need to have a bit of flexibility that's a bit what in the new language is also brought up and on the other side we heard today a few times legal certainty is important right and exactly in the concept of the plausible information you see the flexibility on one side and the need to specify better what it means what means means an objective let's say incident or an objective information is it coming out
• 93:30 - 94:00 of agreements mechanism is it coming out from a a report from a a journalist from an NGO from whatever type of investigation which is obviously has to be objective and I think the German supply chain act it is spelled out pretty well so you have certainty clarity on one side and obviously a a bit of flexibility because you can't run behind every allegation that somebody has seen somewhere which might not be
• 94:00 - 94:30 even the truth so you need to have that specification or specifying um of that so-called plausible information um idea and I think that is something that is maybe being defined now i'm not so sure but I think think it could be very helpful to bring in that uh level of clarity right thank you Marian please thank you for the question i think it's very uh on point
• 94:30 - 95:00 uh as with many things when it comes to this legislation this topic the answer also depends on who is answering it uh from uh if I put my put myself in the shoes of a company perspective I very much echo what has just been said there's an issue of legal certainty what does plausible mean who needs to receive that information uh does it need to be the CEO to be a certain set of people people within the company what is plausible uh yeah do you have a
• 95:00 - 95:30 reasonable delay between knowing and acting so that all requires legal certainty which in my opinion is not there at the moment in the current draft uh stepping back into a more civil society perspective we are highly critical of this proposal and we have been critical also towards its version in the German legislation because the facto you can make the argument that it turns civil society organization trade unions a little bit into watchd dogs and shifts the burden of enforcement beyond
• 95:30 - 96:00 tier one on producing reports investigations etc and yeah that's not exactly the role that civil society is supposed to play at least not in the context of this um this legislation so so we are also critical in that respect okay and Alexandra please well I I think I just fully agree with my fellow speakers and maybe just to say that you know from um my my experience I think I've seen so many times the cases where
• 96:00 - 96:30 actually certain important bits were included in retitals and actually then they were kind of a little bit forgotten and the problem is that actually retitals they have no legal value I mean there you know they just kind of explain so actually you know all the important provisions they should be in the text and then the question is like Indeed companies applying it will they actually read the retitals and really properly understand you know maybe they they and and also some of them they might be actually just shield themselves because
• 96:30 - 97:00 look I think there are really a lot of good companies and great guys you know like Ferrer for instance you know trying to really do their you know good job and and and some others but you know there are also the companies you know that might just approach it as a kind of you know compliance exercise and actually they might be even using then this kind of provision saying like oh you see we don't have to go beyond that so yeah we're we're not going to do that and and maybe they not will not even dive into the rituals
• 97:00 - 97:30 thank you any other questions um if I may um direct a question perhaps to the commission um on um on the timeline what what are your expectations as regards how efficiently these proposals could be fasttracked
• 97:30 - 98:00 well I think in the council good progress is being made on the uh stop the clock uh proposal when it comes to the CSRD and we are hopeful that uh the process will be will be speedy uh also on the content uh directive so that we can have an agreement this year in the meantime I think and to come back to a point which was made byme United um we may want to adopt a
• 98:00 - 98:30 recommendation uh uh on the VSME standard to transpose uh the VSME standard as it is now uh to give legal certainty to uhmemes uh and once the legislation I'm talking about the CSRD here is adopted uh then uh we would get back to the delegated act uh to uh notably on the VSME standard to make sure that uh it is
• 98:30 - 99:00 consistent with the level one text that has been agreed so if everything goes well negotiations and wrapping up the negotiations this year and very quickly afterwards uh the uh the delegated act uh for for theme standard and then we'll need a little bit more time to finalize uh the ESRS standard and there we're waiting for input from uh from ERA of course so that will take a little bit more time into into next year
• 99:00 - 99:30 normally any other questions please do take advantage of the fact that we have a very wide array of speakers please go ahead thank you so I my name is Jimea i represent the European Flavor Association so the industry that creates the flavorings that go to the food and I know we do not have a crystal ball here but I was wondering if maybe the MEPs
• 99:30 - 100:00 will have a better understanding of what are the chances of the legislation being approved also at the parliament and what happens if there's not a an agreement then what will be the role of the commission then thank you this is a um very important time that we are
• 100:00 - 100:30 discussing about several uh port so what about the implementation uh we we are at the beginning and we try to uh have a a clear uh a clear um approach about demandments and uh what we can uh change if change is a is to make because now I understand that
• 100:30 - 101:00 from the discussion we have different opinions so it's better than uh if we read exactly make a clear uh a clear opinion about the topic because uh it is uh very difficult to to understand if we are doing the right thing also because when we sp when we speak about simplification we all agree but the meaning is this
• 101:00 - 101:30 this one so what about balance uh um small and medium enterprises the big the distribution so uh if you ask me what the chance to approve simply we can approve but if we ask me uh how we can change this is a very little bit difficult so if we can
• 101:30 - 102:00 uh join in clear way how to uh how to amend uh how how how can we can improve how we can implementation or we change this is a little bit difficult to have an answer but it is clear for me that it is the need to to to go okay thank you very much um maybe one last question
• 102:00 - 102:30 okay I see I see none oh Nick go ahead yes hello my name is Nick Donheim from your commerce representing uh European retailers and wholesalers so Mitro is for example one of our members and I think we can only echo that uh what a said about the really unique position our members have in the in the retail wholesale sector um and because we have this unique position I think one question always comes up how do we engage with a lot of these suppliers and if there's maybe a way beside standards
• 102:30 - 103:00 and legislation to have common be tools or platforms and that's maybe maybe a a chance for the European Commission or the member states to step in and I know DJ Fisma had two conferences last year to bring also these initiatives that are there now at at member state level also to help small companies um in order to yeah support them and I think also as M United mentioned the tools that need to be developed so is there maybe besides legislation also something that's need
• 103:00 - 103:30 to be looked at be it the platform where everyone can connect data and then maybe applying the the only once principle then maybe several large companies that have the same supplier can then get the information there and the small theme supplier only needs to upload once um yes and I think the general spirit of harmonization standardization um and as CI is still relatively new and the first companies are now reporting I think we still at the beginning of this process and there are a lot of people out there thinking about this but maybe that's a
• 103:30 - 104:00 last question to raise and uh to whom did you did you want to direct uh your question i think probably the commission but also we have Ferrerero and SM United for example no I think it's it's it's early days i I agree that we we we should not only look at uh establishing rules we need to make sure that they can be implemented uh in an easy and uh and
• 104:00 - 104:30 efficient uh way uh and we need to be able to guide notably in doing that uh the uh sectoral standards were there to to help also so now they're out of the picture so we need to to see what we do to make sure that companies can easily uh implement uh uh what they have to uh to do i think we have an open mind i mean we've been consulting a lot on these matters recently i think the process will will
• 104:30 - 105:00 continue we have a little bit more time now with the stop the clock proposal which is likely to be adopted so we should use that time in order to see how we can indeed ease implementation uh and make it as efficient as uh as possible and I'm sure we'll have opportunities to discuss the matter anything to add uh please Veronica thank you yeah I
• 105:00 - 105:30 think indeed uh it's going to be crucial as I mentioned already before stop the clock is great but we shouldn't now take the time to think too long and again arrive too late with with the support tools it's going to be crucial that we roll out i'm thinking about what happened with GDPR half of Europe was going crazy um there were um several consultants who earned a shitload of money on the back of ourmemes and I've already last year when I was in a panel at EFRA um and I might better not say
• 105:30 - 106:00 this because I might be that in a few months then but over my dead body this is going to happen again um we put in place rules we also have to ensure the rule the tools um we have several organizations in in our membership who are already looking in how they can support their their uhmemes it's going to be crucial that commission now also has a look that we uh ensure outreach that we ensure that we get best practices up and that we can do uh an
• 106:00 - 106:30 outroll throughout Europe to make sure that we um don't create again an aversion towards the European Union because I remember when we had uh entrepreneurs discussing on CSRD CSL D that one of the things that was put forward was we have always been strong advocates of the European Union But if you want us to turn against then please continue in this way and that's the last thing that I want to have as an organization the last thing that entrepreneurs want i think that's the
• 106:30 - 107:00 last thing that Europe needs at the moment so we have to make sure that we can that we can provide the support that they need if they have to report that they can do it in an easy way that they have sufficient time to put it in place it's not just providing a few data to get those data you need to put in place a whole system of collecting those data storing those data being able to report on those data and that's not like in the
• 107:00 - 107:30 in the 80s with the shoe box with the invoices that time has been long gone and that's really something that we need to get here working about a lot of things that we want companies to provide we need to make it practical and feasible for them to do so okay thank you very much um well at this point uh before I leave uh the floor to uh Petroki um for the closing
• 107:30 - 108:00 remarks I just wanted to thank you everybody for being here with us thank you to the presenters um speakers uh thank you for your questions um I would like to remind you that um in case uh you want to join the European Food Forum um on on our future discussions please do contact Louisani who's uh here with us um or write to her um an email at um
• 108:00 - 108:30 info@ European foodforum.eu um the next EFF meeting is going to take place already um on the 25th of March and it's going to be titled Empowering Consumers and Business in the Green Transition Navigating EU policy on green claims um so um very much um uh looking forward to seeing you there and um now with the ball uh assuming in the European Parliament's court uh I would
• 108:30 - 109:00 like to invite um our honorable member of the parliament to to close these discussions um please the floor is yours first of all I have to admit that Veronique was very well prepared so now uh jokes aside this is a an extremely difficult topic
• 109:00 - 109:30 uh because in the last legislation we uh the parliament came out and the commission came out with a lot of regulation and directives which were extremely ideological and Taliban and uh they didn't look at uh the matter of economy jobs and so on you know once for all the limitation of pesticides which applies to the European producers not to the extra European producers so that I can buy corn from Canada where they use
• 109:30 - 110:00 two and a half time the f of farmers in their production so they double their production rate per acre uh put it on a ship travel 7,000 kilometers emitting CO2 then 1,000 kilome emitting CO2 and it comes to Milano and at cost which is lower than what we can produce locally uh so my opinion the commission has some uh
• 110:00 - 110:30 some things to fix because they didn't realize how much damage they did to our own production to our own uh culture to our own uh habits and historical things yeah um other than that um uh in reality the uh you were mentioning the omnibus simplification uh which was a in my opinion very
• 110:30 - 111:00 positive approach but it was not sufficient uh because there are still a lot of sector not only your sector but which has incredible amount of uh uh bureaucracy and cost to follow the European rule it will step in the right direction that but that what I can say but uh u remember also that uh and I don't want to uh depress you uh that there are a lot of
• 111:00 - 111:30 regulation and direct which are going to affect uh your life that start from uh you know the PPWR the packaging the CLP uh which uh for example I was I was a shadow reporter on CP but They want to add the mandatory uh information regarding gender equality animal welfare CO2 emission in 27
• 111:30 - 112:00 different languages and they did not accept the concept of using a QR code because they said not every European citizens had a telephone which for me was ridiculous but whatever uh luckily they didn't do that because otherwise you should have done a book like this for every product you were producing and selling in the distribution uh uh system um I do understand that uh uh the um omnibus
• 112:00 - 112:30 onification is something but not enough on taxonomy regulation but again uh remember also that uh and and this is very difficult to understand but will come on on your shoulder uh also the the the sebum ETSs deforestation and all those regulation which are going to be tough for the European producer and
• 112:30 - 113:00 transformers and distribution system because you know I had a talk with the with the commission regarding luckily they they postpone for example the forestation but the idea was that the European importer of uh any type of vegetable goods from uh South America from whatever had to uh certify that uh the production was not done uh with
• 113:00 - 113:30 deforestation and he was like so I asked how how do you do that uh we can give you the utilization of a satellite so you can uh it's like I mean I I imagine the not the small uh industry I'm talking about a micro industry the idea this this guy looking at a satellite who they find that is
• 113:30 - 114:00 importing animals from Costa Rica and that was not uh causing deforestation killed me because I mean it's over my head but anyway um there are a lot of problems uh we are aware of it we are fighting this legislation uh on a on a moderately optimistic uh note uh is a little more pragmatic so
• 114:00 - 114:30 I think we can uh fix a lot of uh strength thing that we did the last legislation um don't be shy come to me come to Elena uh and vice president she's vice president and uh uh we work like maniacs so bring us the problem in a very clear and easy way and we try to solve it so
• 114:30 - 115:00 that's it thank you for coming here because immunion this is a treasure that we have in Europe the food the transformation our culture everything else so we do need to do everything we can do to preserve it thank you to your work thank you very much and Mr donatan would you like to add something no just a thanks for you and I
• 115:00 - 115:30 think that my colleague has put the stress about what what for us is food uh some uh key words impact because we need to have an assessment as clear as we can certaintity because all the time we change uh the regimementary maybe we we are not simplifying but the
• 115:30 - 116:00 contrary and third third word is balanced because we have to to take together different interests so as my colleague Fi has said we are here to understand better as we can uh we have a Liselle is very precious for us to give us the correct information and thank you for your presence here thank you
• 116:00 - 116:30 [Music]