Finnwatch ry

It is clear that the current public procurement directive is not fit to scale business respect for human rights and the environment. As such, we support the review of public procurement directives as there is a pressing need for a transition to sustainable business models.

Finnwatch welcomes the revision of public procurement directives and this opportunity to provide feedback for it. The EU has in recent years introduced new sustainability rules for companies, such as the Corporate Sustainability Due Diligence Directive and the Corporate Sustainability Reporting Directive, which introduce sustainability due diligence obligations and related reporting duties for in-scope companies.

Finnwatch welcomes the initiative to expand the scope of the carbon border adjustment mechanism (CBAM) to downstream products and encourages the commission to also consider expansion to new products groups. The mechanism has multiple overlapping benefits for the goals of climate policy.

The EU Commission's calls for simplification of the tax system are reasonable, given the administrative burden of navigating 27 distinct national tax systems. However, it is important to consider carefully revisions to directives such as ATAD in order not to undermine their policy objectives. Many proposals framed as simplifications risk creating more space for profit shifting and aggressive tax planning.

In its response, Finnwatch is focusing only on the proposed changes to the battery due diligence obligations. Finnwatch does not support the Commission's proposal to reduce the scope of the application of certain due diligence obligations in the batteries regulation by extending the exclusion clause that currently applies to companies with less than 40 million euros turnover to companies with less than 150 million…