Pro Ethical Trade Finland
Eetti
Pro Ethical Trade Finland (Eettisen kaupan puolesta ry – Eetti) is a non-profit organisation that promotes trade justice, sustainable value chains and ethical consumption.
ID: 541115541213-34
Lobbying Activity
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
12 Jun 2025 · Employee rights in the textile industry
Response to Effectively banning products produced, extracted or harvested with forced labour
18 Jun 2022
Pro Ethical Trade Finland is a Finnish non-profit organisation that promotes trade justice, sustainable value chains and ethical consumption. Pro Ethical Trade Finland welcomes the European Commission’s initiative to effectively ban products produced, extracted or harvested with forced labour and the opportunity to contribute to this Call for Evidence.
It is our view that, to be efficient and impactful, such ban on products linked to forced labour should include the following elements:
- A border mechanism that enables blocking products at the EU port of entry should be complemented with a market mechanism that would allow products to be removed or recalled from circulation across the EU market; such combination should be prioritised over a purely market-based mechanism.
- The mechanism should include a remedy mechanism to ensure justice for victims of forced labour, as also expressed by the European Parliament. Remediation should be a prerequisite for lifting any ban. Such remediation must be designed in collaboration with workers, trade unions, labour rights organisations and other legitimate representatives.
- In addition to blocking products imported by specific companies, the public authorities should be able to impose regional restrictions, to be used eg. in cases of state imposed forced labour where due diligence cannot be performed.
- There should be a mechanism in place to allow stakeholders to submit complaints and concerns on forced labour to public authorities on companies, products, containers, or regions.
- Regarding the identification of forced labour in supply chains, the ILO forced labour indicators should be considered.
- Currently, the EU does not disclose custom data, nor is an obligation to map and disclose supply chain information included sufficiently in the CSDDD initiative. Transparency in both would be crucial for monitoring of human rights violations, in particular regarding forced labour. The Union Customs Code should be amended to ensure customs data is not confidential and can be disclosed publicly, as well as to require importing companies to disclose the name and address of the manufacturer to the relevant customs authorities. Considering the limited scope of the current CSDDD proposal, the instrument should also include supplementary requirements for supply chain transparency. The instrument should be complimentary to the iterative due diligence process required in the CSDDD.
- It should be ensured that relevant public authorities have sufficient capacity and resources to effectively implement the ban. They should collaborate with equivalent authorities in countries implementing similar bans, eg. Canada and USA.
Read full responseResponse to Sustainable corporate governance
23 May 2022
Pro Ethical Trade Finland is a non-profit organisation that promotes trade justice, sustainable value chains and ethical consumption. Pro Ethical Trade Finland welcomes the proposal for the Corporate Sustainability Due Diligence Directive.
The directive can, with the necessary adjustments, be a crucial step towards minimising the adverse impacts of unsustainable business practices on workers, communities and the environment worldwide.
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. Importantly, the directive 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, the European Parliament and EU Member States must address the proposals' many shortcomings and loopholes during the legislative process.
The proposal includes many components that risk undermining its effectiveness and impact. 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.
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