The International Dairy Foods Association (IDFA) today warned that European Union due-diligence requirements are increasing costs and administrative burdens for U.S. dairy processors and farmers, including companies that do not sell products directly into Europe. IDFA is urging the Office of the U.S. Trade Representative (USTR) to continue pressing the European Commission to limit the extraterritorial application of these requirements and secure meaningful relief for U.S. companies.
In comments recently submitted to USTR, IDFA urged the Administration to make limiting the extraterritorial application of the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) and related measures a priority in its engagement with the European Commission and to secure an exemption for U.S. companies. To support those discussions, IDFA commissioned Steptoe LLP to conduct a legal analysis comparing international labor standards with U.S. federal and state laws applicable to dairy operations.
The legal analysis examines six areas of worker protection—including child labor, forced labor, freedom of association, just and favorable working conditions, occupational health and safety, and nondiscrimination—and identifies where U.S. law provides protections comparable to international standards and where the two regulatory frameworks differ. The analysis found that U.S. law and international standards often take different approaches to worker protection, with international frameworks increasingly emphasizing affirmative due diligence, documentation, stakeholder engagement, grievance mechanisms and supply-chain monitoring that generally are not required under U.S. law.
“The United States has extensive laws protecting workers and the environment, and the U.S. dairy sector strongly supports the protection of human and worker rights,” said Michael Dykes, D.V.M., president and CEO of IDFA. “But our trading partners should respect our regulatory system just as we respect theirs. U.S. companies should not be required to duplicate or layer foreign regulatory requirements on top of the laws they already follow simply because those requirements are being applied through global supply chains.”
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