Towards an integrated implementation of EU sustainability legislation

In recent years, the European Union has developed an increasing number of legislative instruments that legally embed responsible and sustainable business conduct. Examples include the CSRD, CSDDD, the Deforestation Regulation, the Forced Labour Regulation, and Extended Producer Responsibility as part of EU legislation on circularity. For Dutch businesses, this results in a growing number of obligations, ranging from reporting requirements to due diligence duties across international value chains. To support companies in meeting these obligations more smartly and efficiently, the Dutch Ministry of Economic Affairs has launched the pilot project “Integrated Implementation of EU Sustainability Legislation”. This project explores how companies can apply the various sustainability rules in a coherent manner. An expert working group, led by a multidisciplinary team of scholars from Erasmus University Rotterdam, is developing an integrated implementation methodology.

Initial inventory of potentially relevant legislation.
Initial inventory of potentially relevant legislation.

Objective and structure of the subproject

If companies are required to implement each law separately, this leads to more regulations, more paperwork, and additional costs. This, in turn, makes it more difficult to achieve the intended goals of the legislation — such as the protection of human rights, the climate, and the environment. The European Commission does aim to simplify the rules through the Omnibus proposal, expected in February 2025. However, what is lacking is an integrated approach to existing sustainability rules.

The expert working group has been tasked with two core components: an analysis of the substantive overlaps between existing and upcoming EU sustainability legislation, and the development of a coherent implementation approach. This subproject aims to contribute to a more effective and efficient implementation of legislation by companies, without compromising the substantive objectives of the regulations.

The proposed methodology is partly based on the international normative framework for responsible business conduct, particularly the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This framework underpins the due diligence obligations found in much of the relevant EU legislation. In addition, the working group will explore other opportunities for a coherent approach to the legislation. The most relevant options will be further developed and disseminated to businesses and other stakeholders through other subprojects (including multi-stakeholder sessions, training programmes, and a Community of Practice). Project partners for these other subprojects include FoodFirst, RBConnect, and MVO Nederland.

Composition of the expert working group

The expert working group is led by an interdisciplinary core team of four professors from Erasmus University Rotterdam: Liesbeth Enneking, Professor of Corporate Responsibility & Sustainability at ESL (project lead); Karen Maas, Professor of Accounting and Sustainability and Scientific Director of the Impact Centre Erasmus; Martijn Scheltema, Professor of Private Law at ESL and expert in business and human rights; and Albert Veenstra, Professor of International Trade and Logistics at RSM.

The core team is responsible for guiding the working group, liaising with the other subprojects, and drafting reports on their findings. They work closely with the other working group members, who bring their expertise from various professional backgrounds. These members include Frank Peen (programme advisor at the Human Environment and Transport Inspectorate, involved in developing oversight of the Conflict Minerals Regulation and due diligence), Eva Smulders (CSR advisor specialising in business and human rights and coordinator of the CSR helpdesk), and working group facilitator Manon Wolfkamp (expert, trainer, advisor and facilitator in the field of CSR and public affairs). The working group will be expanded as needed if additional expertise is required.

Brainstorm over mogelijk relevante wetten en samenhang daarvan.
Brainstorm on potentially relevant legislation and their interconnections.

Expected outcomes and next steps

The expert working group’s activities will culminate in a final report, presenting findings and recommendations for an integrated implementation of EU sustainability legislation. Based on these findings, the project partners in the other subprojects will work on disseminating the acquired knowledge and insights to businesses and other stakeholders, thereby facilitating practical application.

The project explicitly does not aim to change existing legislation, but rather to optimise how businesses implement it. In doing so, it ties in with broader discussions on regulatory burden and simplification, as also reflected in the recent Omnibus proposals by the European Commission.

Position of Erasmus University Rotterdam

The university’s involvement in this pilot project aligns with its broader mission to contribute to the resolution of contemporary, complex societal challenges through interdisciplinary research and collaboration with societal actors, thereby creating positive social impact. At ESL, where the subproject is based, the focus lies on a scientific approach to socially relevant legal issues at the intersection of civil law, corporate law, sustainability, and human rights.

Professor
Professor
Karen Maas, Professor by Special Appointment of Accounting and Sustainability
Professor
Professor
Albert Veenstra, Professor of International Trade and Logistics
Related links
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