Shaping the EU CSDDD: LICOP’s Submission & How You Can Respond
The European Commission has opened a key public consultation on the implementation guidelines for the Corporate Sustainability Due Diligence Directive (CSDDD), closing on Friday 14 August.
While the Directive establishes a crucial legal baseline for responsible business conduct and environmental accountability, the forthcoming guidelines will dictate how these standards work in practice. They will influence how companies prioritise risks, engage stakeholders, and ensure fair, workable standards across global supply chains.
The Technical Advisory Committee of the Living Income Community of Practice came together to formulate a response. Below, we share our core recommendations and provide a quick guide on how you can submit your own response before the deadline.
LICOP's recommendations on how CSDDD should treat living income data
“We welcome CSDDD's recognition of an adequate living income. This requires two types of data: household income and the living income benchmark. Benchmarks, where they exist, are cost-effective and available. For household income, companies need to take a risk-based approach: using public data, then moving to localized/primary data to validate higher-risk cases. This granular data isn't always available and can be cost-prohibitive. Guidance is needed on minimum rigor per risk level, and on gaps in either data type. Please read the attachment for elaboration.”
In our submission, we highlight clear, proportionate obligations for companies:
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A Two-Stage, Risk-Based Approach to Household Income
Stage 1 (Prioritisation): Companies can use cost-effective, publicly available national/regional data to screen for high-risk crop and origin pairings.
Stage 2 (Validation): Where high risk is identified, companies should gather localised primary data to understand specific risks and design effective remediation.
Streamlined Data Sharing: Upstream suppliers should share data directly across their buyer networks to prevent multiple buyers from running redundant, burdensome surveys on the same farmers.
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Leveraging Credible Living Income Benchmarks
LICOP recommends that CSDDD guidance explicitly direct companies toward established benchmark repositories aligned with ILO principles.
Guidance must also clarify how companies should handle regions where no established living income benchmark currently exists.
How to submit your own response to the EU Commission
The European Commission's consultation closes on Friday 24 July (midnight Brussels time). We encourage you to draw on LICOP's reflections to inform your own submission.
1. Access the Portal: Visit the EU Consultation page for more information. (Note: If you are submitting on behalf of an organisation, make sure you are registered on the EU Transparency Register ).
2. Create an EUSurvey login: An active EUSurvey account is needed to complete submission.
3. Submit your feedback: You do not need to answer every question! You can navigate directly to the sections relevant to your expertise and adapt or attach LICOP's position to support your response.