- On 14 August 2026, the US Government published formal comments critical of the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) and requesting a reduced scope for foreign-owned companies.
- The US warned that it would take “any actions necessary to address unreasonable burdens on US commerce”.
Key proposals
- Non-EU companies out of direct scope: The US called for deletion of Article 2.2(a)–(c), and removing non-EU companies from direct CSDDD coverage. ; EU subsidiaries of foreign groups could remain in scope where they independently meet applicable thresholds.
- EU-linked due diligence only: The US has asked that due diligence requirements apply only to activities and products linked to the EU market — limiting their reach into US companies’ wider global operations and value chains.
- Presumed compliance: The US has asked that due diligence requirements be reduced or eliminated for companies operating in “high-quality regulatory jurisdictions”, including the US.
- Slightly narrower stakeholder definition: The US requests clarificationy of stakeholder engagement requirements that apply only to stakeholders who could ‘reasonably be expected’ to be affected by a company’s activities, while trade unions would remain explicitly in– scope.
- EU revenue basis for fines: The US proposes that penalties be calculated solely based on revenue generated from activities within the EU, rather than a company’s global net turnover.
- Risk-based verification: The US requests that audits, site visits and stakeholder engagement be required only where credible, documented risk cannot be assessed through less burdensome means. The US also proposes that companies should not be required to conduct on-site audits of upstream suppliers that do not directly supply an EU buyer.
- Third-party verifiers: The US raises concerns about insufficient oversight and potentially inaccurate or inconsistent assessments, citing cases where US companies have faced threatened contract termination based on allegedly unreliable third-party verification reports.
- No climate-plan requirements: The US calls for CSDDD guidance not to reintroduce mandatory net-zero transition plans or other related requirements.
- On 23 July 2026, Stop EU Overreach Act (H.R. 9892) was also introduced in the US House of Representatives and would require an investigation into CSDDD, CSRD, EUDR, Carbon Border Adjustment Mechanism and related measures.