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Finnwatch ry

Finnwatch is a Finnish NGO promoting human rights, climate justice, and corporate tax responsibility.

Lobbying Activity

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

17 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

3 Nov 2025 · Sustainability omnibus - update for civil society

Meeting with Kira Marie Peter-Hansen (Member of the European Parliament, Shadow rapporteur) and Transport and Environment (European Federation for Transport and Environment) and

2 Oct 2025 · Sustainability omnibus - update for civil society

Finnwatch urges EU to set 90% domestic 2040 climate target

12 Sept 2025
Topic — Amending the European Climate Law to establish the EU's 2040 climate target.
Message — Achieve 90 percent emissions reduction through domestic action alone without using international credits. Set a separate target for international credits to reach carbon neutrality by 2040. Ensure carbon removals in the emissions trading system are coupled with tighter caps.123
Why — This approach accelerates the timeline for achieving carbon neutrality through domestic investment.4
Impact — Industries relying on cheap international offsets would face higher costs and restrictions.5
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Finnwatch supports expanded carbon border rules and ending free allowances

25 Aug 2025
Topic — The EU seeks to extend carbon border costs to downstream products and prevent circumvention.
Message — Finnwatch supports expanding the carbon border mechanism to downstream products and new product groups. These adjustments must not cause further delays for phasing out free emission allowances. Additionally, the EU should use revenues to support low-income trading partners.123
Why — This expansion helps the organization achieve its mission of promoting responsible business and climate accountability.45
Impact — Low-income trading partners may suffer due to limited capacity to avoid costs or implement pricing.6
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Finnwatch fights plan to weaken battery due diligence rules

8 Jul 2025
Topic — Proposed EU regulation to reduce administrative burdens for small mid-cap enterprises.
Message — Finnwatch rejects raising the turnover threshold for battery due diligence exemptions from 40 to 150 million euros. They propose providing tailored, practical guidelines for smaller companies instead of reducing the regulation's scope.12
Why — The group maintains the strength of sustainability standards by preventing smaller firms from ignoring human rights obligations.3
Impact — Data users and communities lose access to timely information regarding corporate impacts on human rights and ecosystems.45
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Finnwatch opposes delay in battery due diligence rules

8 Jul 2025
Topic — The consultation concerns delaying the implementation of battery due diligence obligations.
Message — Finnwatch requests that the EU maintains the original implementation timeline. They urge regulators to release guidance immediately to help companies prepare.123
Why — Avoiding delays ensures the NGO can continue its work monitoring corporate human rights impacts.4
Impact — Public trust and democratic oversight are weakened by the rapid dismantling of sustainability rules.5
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Meeting with Mika Aaltola (Member of the European Parliament, Rapporteur for opinion) and European Movement International and SOPRA STERIA GROUP

19 May 2025 · EU affairs

Meeting with Aura Salla (Member of the European Parliament)

16 May 2025 · CSDDD and other current topics

Finnwatch demands mandatory human rights and environmental procurement rules

7 Mar 2025
Topic — This evaluation assesses the effectiveness and relevance of EU public procurement directives.
Message — Finnwatch advocates for mandatory human rights due diligence and full supply chain disclosure from contractors. They propose mandatory life cycle environmental assessments using the Product Environmental Footprint methodology. The group also recommends geographical exclusions for products from high-risk areas.123
Why — This shift would expand the market for European companies developing sustainable solutions.4
Impact — Contractors failing supply chain transparency or operating in high-risk regions would face exclusion.5
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Finnwatch urges EU to tighten anti-tax avoidance rules

11 Sept 2024
Topic — An evaluation of the effectiveness of the European Union's Anti-Tax Avoidance Directive.
Message — Finnwatch calls for stricter minimum standards and the removal of various tax exemptions. They recommend lowering interest deduction limits and strengthening rules for foreign subsidiaries. They also propose a new exit tax for wealthy individuals.123
Why — These changes would strengthen national tax bases and improve fair market competition.4
Impact — Large corporations and wealthy individuals would lose access to profitable tax avoidance loopholes.5
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Meeting with Anna Cavazzini (Member of the European Parliament, Shadow rapporteur)

8 Nov 2023 · Customs reform

Response to Revision of the Union Customs Code

13 Sept 2023

Finnwatch would like to thank the Commission for the opportunity to provide feedback on the Commission proposal for a regulation establishing the Union Customs Code and the European Union Customs Authority (and repealing the existing UCC). We believe a comprehensive reform is necessary as it is clear that the existing UCC is ill-fit to address challenges posed by customs work shifting to new tasks such as enforcing EU legislation on environment, human rights and climate change. For a number of years, Finnwatch has been calling for the greater transparency of, and public access to, customs information on trade parties, systematic collection of information on manufacturers of goods entering the Union, centralized system for storing comprehensive customs information, and improved tracking of movement of goods within the Union once they have been released for free circulation (for more details please see our 2017 briefing for more details: https://finnwatch.org/images/pdf/FW_Transparency_of_customs_data_legal_briefing.pdf). Although the Commission proposal in part addresses these specific calls (e.g. according to Art 22. data provided to customs would have to include manufacturer for goods to be released for free circulation), it misses an opportunity to address them in full. The changes to the Customs Code that Finnwatch has been calling for and which are listed above would better enable stakeholders to bring into the attention of undertakings themselves, and of MSs competents authorities, possible adverse human rights and environmental impacts in the undertakings supply chains and gaps in their due diligence processes. As such, they would strengthen the enforcement and human rights impact of a number of EU laws that mandate undertakings to undertake due diligence (most importantly the forthcoming Corporate Sustainability Due Diligence Directive), or that seek to prevent goods made with forced labour from entering the market (i.e. the proposed Regulation on Prohibiting Products Made with Forced Labour on the Union Market). In particular, we regret the failure of the Commission proposal to unequivocally clarify that customs data on trade parties (i.e. importers, responsible economic operators in the Union, buyers and sellers) that are undertakings (with the exclusion of personal data, e.g. names of individuals acting for an economic operator / undertaking) and on manufacturers, suppliers and origin as well as the tariff classification and description of goods should be made publicly accessible in Member States. We urge the co-legislators to add such clarification in the regulation text before its finalisation.
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Finnwatch warns against weakening EU corporate sustainability reporting rules

6 Jul 2023
Topic — Commission consultation on delegated acts establishing standards for corporate sustainability and governance reporting.
Message — Finnwatch rejects making reporting on climate and workers subject to materiality assessments. They demand that disclosures on biodiversity and non-employees remain mandatory rather than voluntary. They also oppose additional phase-ins, arguing companies have had enough time to prepare.123
Why — Robust mandatory reporting enables the organization to effectively monitor corporate human rights and climate impacts.4
Impact — Vulnerable agency workers and the environment lose protections when reporting on these issues becomes optional.56
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Meeting with Heidi Hautala (Member of the European Parliament, Shadow rapporteur)

31 Mar 2023 · Due diligence

Meeting with Gints Freimanis (Cabinet of Executive Vice-President Valdis Dombrovskis) and Clean Clothes Campaign / Stichting Schone Kleren Kampagne and Stichting Onderzoek Multinationale Ondernemingen

17 Jan 2023 · Public access to customs data

Meeting with Henna Virkkunen (Member of the European Parliament)

17 Nov 2022 · EU Corporate Sustainability

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament, Shadow rapporteur for opinion)

8 Nov 2022 · Meeting on Due Diligence

Finnwatch calls for customs transparency to expose supply chain abuses

14 Sept 2022
Topic — The European Commission is revising the Union Customs Code for better enforcement.
Message — Finnwatch urges amending Article 12 to clarify that trade party data is not confidential and can be disclosed. They also seek mandatory collection of manufacturer names to better track forced labor goods.12
Why — Public data access would allow NGOs to identify human rights abuses and verify corporate due diligence.3
Impact — Importers circumventing sanctions or using forced labor would face increased public exposure and investigations.4
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Response to Sustainable Products Initiative

21 Jun 2022

Finnwatch welcomes the initiative to establish a framework for setting ecodesign requirements for sustainable products. Current level of consumption in the European Union is utterly unsustainable and in direct contradiction with the EU goals of stopping climate change and the loss of biodiversity. For example in Finland, our national scientific expert panel on climate change has highlighted the need for Finland to cut down 70% of its per capita carbon footprint. The initiative proposed by the commission aims to address one part of the problem by ensuring that the products sold in the EU are designed to mitigate the harmful impacts on the environment. We find that the initiative includes many important improvements to the situation under the current directive. The requirement to disclose information on the destruction of returned and unsold products is an important step which provides necessary information for the Commission’s delegated regulation to ban destruction where most effective. Banning the destruction of returned and unsold products can curtail the most excessive features of consumer culture that harms the environment. The disclosure requirement and the subsequent ban should not exclude SMEs, as the circular economy requires rapid economy-wide changes. Digital product passports open a new way of increasing the transparency and sustainability of the supply chains. To achieve these goals the passport should require full disclosure of the supply chain including importers, exporters and all the relevant manufacturers and the origins of used raw materials. The digital product passport should be designed to support other relevant upcoming legislation such as Directive on corporate sustainability due diligence and import ban on products produced with forced labor. To ensure that the data is correct and useful, all the information collected for the passports should be freely available in a single open registry. In addition, the passport data should be complemented by opening the customs data on importer/exporter level for public use. We applaud the ban on the use of labels which are likely to mislead or confuse customers, such as companies’ own “certification” marks that lack third party criteria and monitoring. Under Article 5 it is stated that “there shall be no significant negative impact on consumers in terms of the affordability of relevant products”. Finnwatch would like to point out that including true social and environmental costs to the products will make them more expensive, and to a very large extent this is also needed in order to curtail current unsustainable excessive consumption. The possible negative social impacts should be tackled in other policies (e.g. tax and social policies). Just transition requires the Commission to take into account the need to reduce consumption and increase social justice such as income distribution in all its legislative initiatives.
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Finnwatch urges EU ban on products made with forced labour

20 Jun 2022
Topic — The EU initiative aims to prohibit products made with forced labour on the single market.
Message — Finnwatch supports a ban as a necessary supplement to due diligence rules, specifically targeting state-imposed forced labour. They demand transparency through public customs data and a registry of sanctioned entities. The ban should require companies to remedy harm before a ban is lifted.123
Why — Enhanced supply chain transparency would allow the NGO to monitor corporate conduct and report violations effectively.4
Impact — Businesses relying on exploitative labour or state-imposed systems would face market exclusion and sanctions.5
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Response to Sustainable corporate governance

20 May 2022

Finnwatch, a business and human rights NGO based in Helsinki, Finland, welcomes the long-awaited commission proposal for the Corporate Sustainability Due Diligence Directive. At times when we are facing multiple crises from covid-19 to climate emergency, rapidly accelerating holocene extinction and a war in Europe, this directive could represent a landmark step towards minimising the adverse impacts of unsustainable business practices on workers, communities and the environment worldwide. Importantly, the directive also has the potential to considerably advance corporate accountability and access to justice for victims of corporate human rights abuse. However, for the directive to reach its potential and truly become the game changer it is intended to be, the European Parliament and EU Member States must address the proposals' many shortcomings and loopholes during the legislative process. The CSDDD proposal contains many ambitious elements, including corporate duty to conduct human rights and environmental due diligence with a view to addressing adverse impacts in the full value chain, obligation to adopt a climate transition plan, and provisions on public enforcement and civil liability. However, the proposal also includes many components that risk undermining its effectiveness and impacts. These include, for example, the limited company scope, the novel concept of “established business relationships” which is used to limit the scope of due diligence requirements contrary to the international standards on corporate responsibility such as the UNGPs and the OECD guidelines, heavy reliance on contractual assurances, cascading and third-party verification, absence of an explicit duty to reduce climate impacts and implement the climate transition plan, and lack of provisions on fair distribution of burden of proof in civil cases. For the purpose of strengthening the proposal, we encourage the co-legislators to take into account the reflections and recommendations in the attached file put together by European Coalition for Corporate Justice of which Finnwatch is a member of.
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Response to Carbon Removal Certification

29 Apr 2022

Finnwatch julkaisi kesäkuussa 2021 raportin päästökompensaatioiden markkinasta Suomessa. Raportti käsittelee kattavasti myös suomalaisia maankäyttösektorin hankkeita, joten sen havainnot ja suositukset ovat relevantteja hiilen poistamisen sertifiointia koskevan esityksen kannalta. Raportin pdf-versio on liitteenä ja se on luettavissa myös osoitteessa https://finnwatch.org/fi/julkaisut/anekauppaa-vai-ilmastotekoja
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Meeting with Diana Montero Melis (Cabinet of Commissioner Jutta Urpilainen) and European Coalition for Corporate Justice

14 Sept 2021 · upcoming proposal on sustainable corporate governance and mandatory due diligence

Response to Action Plan on fight against tax fraud

1 Apr 2020

We greatly welcome EC’s Action Plan to fight tax evasion and make taxation simple and easy. The need for increased measures to tackle tax evasion and tax avoidance is bigger than ever, as the economic impacts of coronavirus are to be significant and at the same time just transition to climate resilient society also requires public funding. The Action Plan points out correctly that vast amounts of money are currently lost due to tax evasion. However, there is no reason to limit the scope of the Action Plan to (illegal) tax evasion only as the costs of (legal) tax avoidance are very likely to be much greater. Thus, we strongly suggest that tax avoidance - both by corporates and individuals - is included in the key problems covered by Action Plan and the measures suggested to tackle the problems are updated correspondingly. In regard to the concrete steps presented in the Action plan, we warmly welcome the objectives of simplification and modernisation of tax rules as well as the development of an External Strategy to guide new tax initiatives with external implications (incl. developing countries). However, we think the simplification and modernisation should not be limited to VAT rules - instead, corporate income tax should be a top priority. In practice, we strongly suggest that EU-wide tax harmonisation measures such as CCCTB, digital tax and minimum effective tax are taken into the Action Plan. These measures would lighten the administrational burden of internationally operating businesses by harmonising tax rules in EU area. They would also help to tackle tax avoidance as the loopholes caused by non-harmonised tax systems would no longer exist. Further, the digital tax, particularly, would broaden the tax base and put an end to the tax avoidance of major digital companies. Some may argue that there is no point promoting CCCTB, digital taxation or minimum tax on EU level as all these aspects are currently discussed as part of the OECD tax reform. However, it does not look likely that the OECD tax reform process would either be completed in the near future or lead to a solution that would ensure a fair and effective international tax system. Thus, it is still important to look for more progressive solutions on EU level. New transparency measures are also needed, and introduction of public CBCR would be the most efficient way to increase the transparency on tax information. As regards to External Agenda, we suggest that EC carries out a careful in-depth analysis of the effects that current and planned EU tax policies (both EU-wide and member country policies) have on developing countries.This analysis should then guide any future measures taken. Increased technical assistance to developing countries is highly recommended. Further, EU should support increasing the role of UN tax committee (or other relevant UN body) in the discussions relating to global tax rules reforms. This would enable the participation of all countries on an equal footing, whereas only a limited number of developing countries are involved in the OECD Inclusive Framework. Following the wider scope proposed above, concrete steps relating to tax avoidance should also be added. These include tightening the anti-avoidance rules included in ATAD as the current minimum level requirements are rather loose in the light of OECD BEPS recommendations. Interest limitation and CFC rules, in particular, still leave too much space for profit shifting. Finally, measures to tackle tax avoidance of individuals is also essential, since this phenomenon is not only decreasing the tax income in many countries, but also leading to increased inequality. The root cause, in many countries, is the lower level of capital gains taxation as compared to ordinary income taxes. Setting minimum levels for capital gains taxation could help to ease the situation and imposing an EU-wide exit tax for individuals would help to secure the tax bases of member states.
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Meeting with Isabelle Magne (Cabinet of Vice-President Cecilia Malmström), Maria Asenius (Cabinet of Vice-President Cecilia Malmström) and

28 Mar 2017 · Responsible supply chains and how to increase transparency