ECCJ welcomes the publication of the European Commission’s Staff Working Document...ECCJ considers that the main value of the SWD is to inform the future process towards a real European strategy and action plan to implement the UNGPs – a robust process, with participation of stakeholders, which is, unfortunately, still to be initiated despite the commitment made in 2011...ECCJ does not share the Commission’s conclusion that much has already been achieved in the process of implementing UNGPs. While it is true that the EU has been one of the global frontrunners in embedding UNGPs in its policy framework, we believe that the Commission overstates the concrete effects of its actions...ECCJ also disagrees with the SWD’s assertion that the EU has a limited role and competences in the field, allowing it to adopt a back-seat approach and place the onus largely on Member States...