In recent years, the European Union has developed a growing number of legislative instruments that legally enshrine responsible and sustainable business practices. Examples are the CSRD, the CSDDD, the EU Regulation on Deforestation-free Products, the EU Forced Labor Regulation and the Extended Producer Responsibility in EU-legislation on circularity. For Dutch companies, this results in an increasing number of obligations, ranging from reporting requirements to due diligence obligations in international value chains. To help them meet these obligations in a smarter and more efficient manner, the Dutch Ministry of Economic Affairs has started the pilot project “Integrated Implementation of EU Sustainability Legislation”. This project investigates how companies can apply the diverse sustainability regulations in a coherent way. An expert working group led by a multidisciplinary team of academics from Erasmus University Rotterdam is developing an integrated implementation methodology.
About the pilot project
Companies are facing more and more European laws relating to corporate responsibility and sustainability. Examples are the CSRD, the CSDDD, the EU Regulation on Deforestation-free Products, the Forced Labor Regulation and the Extended Producer Responsibility in EU legislation on circularity. Each law has its own goals and rules. Also, these laws are implemented by different ministries and regulators. Even Dutch companies that are not directly covered by these laws are more likely to receive questions from other companies in their chain.
If companies have to implement each law separately, it creates more rules, more paperwork and extra costs. This makes it more difficult to achieve the goals of the laws - such as protecting human rights, climate and the environment. The European Commission seeks to make the rules easier with the Omnibus proposal presented in February 2025. But what is missing is an integrated approach to the existing sustainability rules.
The Dutch Ministry of Economic Affairs has therefore started a pilot project: “Integrated Implementation of EU Sustainability Legislation”. This project develops an integrated approach that allows companies to apply the various sustainability rules in a coherent way. In doing so, it connects to what companies are already doing and to existing international guidelines, such as those of the OECD on responsible business conduct and those of the United Nations on business and human rights.
An integrated approach helps companies to comply with legislation in a smarter and more efficient manner. This prevents unnecessary work, lowers costs and makes it clearer what is expected of them. This approach should support companies with concrete steps, so they do not end up in a tangled web of rules and regulations. The result is more overview and consistency and less regulatory burden. An advantage is also that it contributes to strengthening Dutch value chains and thus to the earning capacity and security of supply of Dutch companies.
It is not the intention of the pilot project to change laws or legislative processes. Rather, it is about integrating their implementation by companies.
The pilot is conducted through a transparent process that includes multi-stakeholder dialogue sessions. A group of experts first develops a proposal. This is then discussed in sessions with various stakeholders. To disseminate knowledge properly, there will be training sessions and a Community of Practice for industries and companies. With this approach, the Ministry of Economic Affairs wants to make it easier for companies to ensure that their business remains future-proof. A smarter application of the rules will make sustainable business more feasible and attractive for Dutch companies.
About the expert working group
If companies have to implement each law separately, this creates more regulatory burdens, more paperwork and additional costs. That makes it harder to achieve the laws' goals - such as protecting human rights, climate and the environment. The European Commission does want to simplify the rules with the Omnibus proposal it presented in February 2025. But what is missing is an integrated approach to the existing sustainability rules.
The assignment to the expert working group consists of two main components: an analysis of content overlap between existing and upcoming EU sustainability legislation, and the development of a coherent implementation approach. In doing so, the sub-project aims to contribute to a more effective and efficient implementation of laws and regulations by companies, without compromising the substantive objectives of the regulations.
The intended methodology is partly based on the international normative framework for corporate responsibility and sustainability, in particular the UN Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises. This framework forms the basis for due diligence obligations in many of the relevant EU laws. In addition, the working group will identify other options for addressing these laws in conjunction. The most relevant options will be further elaborated and implemented through the other sub-projects (multi-stakeholder sessions, the development of a training for branch organizations, and a Community of Practice).
The expert working group is led by an interdisciplinary core team consisting of four professors from Erasmus University Rotterdam: Liesbeth Enneking, professor of Corporate Responsibility & Sustainability at ESL (project leader); Karen Maas, professor of Accounting and Sustainability and scientific director of the Impact Centre Erasmus; Martijn Scheltema, professor of Private Law at ESL and specializing in business and human rights; and Albert Veenstra, professor of International Trade and Logistics at RSM.
The core team is responsible for leading the working group, liaising with the other sub-projects and preparing reports on their findings. In doing so, they work closely together with the other working group members, who bring expertise from different backgrounds (government, supervision, communication, business).
The work of the expert working group will result in a final report setting out the findings and recommendations for the integrated implementation of EU sustainability legislation. Based on the findings of the working group, the project partners in the other sub-projects will work to disseminate the knowledge and insights gained to companies and other stakeholders, in order to enable their application in practice. The project explicitly does not focus on changing existing legislation, but on optimizing its implementation by companies. In doing so, it aligns with broader discussions on regulatory burden and simplification, as reflected in the European Commission's recent Omnibus proposals.
Erasmus University Rotterdam's involvement in this sub-project fits in with its broader mission to contribute to the solution of contemporary, complex societal issues through interdisciplinary research and collaboration with civil society actors, thus creating a positive social impact. At ESL, where the sub-project is based, there is a strong commitment to conducting scholarly research into societally relevant legal issues at the intersection of civil law, company law, sustainability and human rights.
Want to know more about this project or make a contribution? Send an email to enneking@law.eur.nl.