Brussels, June 2025
On February 26, the European Commission introduced the ‘Omnibus Simplification Package’, proposing major amendments to core EU sustainability legislation, including the Corporate Sustainability Due Diligence Directive (CSDDD). While presented as a streamlining effort, the proposed changes significantly weaken the CSDDD—particularly for high-risk sectors like minerals and metals—and threaten to roll back years of progress on corporate accountability, responsible sourcing, and human rights protection.
This move not only puts at risk the EU’s credibility as a global leader in responsible business conduct but also fails to deliver the policy coherence and stakeholder engagement expected from such a major legislative shift. We provide a brief overview of what the envisaged changes under the Omnibus Package would mean for the minerals and metals sector, identifying three focal aspects.
1. Limiting Due Diligence to Tier 1 Suppliers Defies Reality
The Omnibus proposal suggests that companies can fulfill their due diligence obligations by assessing only their immediate (Tier 1) suppliers. This approach is dangerously inadequate for sectors like mining, where well-documented human rights abuses and environmental harm often occur far upstream.
Reducing due diligence to Tier 1 creates a “box-ticking” exercise, shifting responsibility away from companies and placing the burden on communities and civil society to uncover and report violations. This reverses the risk-based approach enshrined in the original CSDDD, the UN Guiding Principles on Business and Human Rights (UNGPs), and the OECD Guidelines for Multinational Enterprises.
Ironically, the Commission’s own proposal acknowledges that deeper supply chain engagement enhances resilience and competitiveness—yet weakens the very obligations needed to achieve those benefits.
2. Shrinking Stakeholder Engagement Undermines Human Rights
The Omnibus package drastically reduces meaningful stakeholder involvement by:
In the mining sector, these changes are especially harmful. Many rights holders—such as Indigenous Peoples or artisanal miners—are highly marginalized and often lack the means to participate directly in corporate processes. Their representation by civil society organizations is vital.
With over half of transition minerals located on or near Indigenous lands, inclusive stakeholder engagement is not just a best practice—it is essential to preventing harm and designing appropriate, context-specific safeguards.
3. Weakened Civil Liability Erodes Access to Justice
The proposal eliminates the CSDDD’s requirement for a harmonized civil liability regime and removes the option for representative actions, leaving enforcement to the discretion of individual Member States.
This undermines access to justice for communities affected by corporate abuse—particularly in the mining sector—who often lack the resources to pursue individual legal cases across complex legal systems. Without third-party representation, such as NGOs or trade unions, accountability becomes even less attainable.
Instead of strengthening corporate responsibility, the Omnibus package risks turning due diligence into a symbolic gesture, devoid of enforcement or consequence.
The Omnibus proposal not only conflicts with international standards but also threatens to damage the EU’s own strategic goals. By diluting due diligence obligations, it undermines the objective of securing resilient, ethical supply chains for critical minerals—exposing EU businesses to greater legal, reputational, and financial risks.
In a time of growing demand for transition minerals, and increasing scrutiny of mining practices worldwide, the EU must lead by example—not backtrack on hard-fought gains in human rights and environmental protection.
Together with 12 organisations undersigned a statement, attached below, are calling the EU policymakers to reject the Omnibus proposal in its current form and:
Only with a robust, coherent, and inclusive framework can the EU maintain its leadership and truly promote responsible business conduct in the global minerals sector.
For more info, please contact: martina.matarazzo@resourcematters.org
