Osaka Expo 2025 and the Future of Sustainability & Legal Practices
August 2025
Shinwa Law / BHR Lawyers Network Japan
I. Introduction — Sustainable Future Society Envisioned by Osaka Expo 2025
The 2025 Osaka–Kansai Expo (hereinafter, the “Osaka Expo 2025” or the “Expo”), currently underway, has adopted “Designing Future Society for Our Lives” as its overarching theme and aims to contribute to the achievement of the Sustainable Development Goals (SDGs)[1]. With 2025 leaving five years until 2030—the target year for achieving the SDGs—this is an extremely important year to accelerate efforts. The Expo seeks to serve as a platform for “SDGs + beyond,” enhancing sustainability for the attainment of the SDGs and for the future that lies beyond them. Another objective of the Expo is the realization of Society 5.0, Japan’s national strategy, which likewise aims to contribute to a sustainable society through innovative technologies.
Under these objectives, the organizer—the Japan Association for the 2025 World Exposition (hereinafter, the “Association”)—is proactively advancing sustainability initiatives in the preparation and operation of the Expo[2]. Many pavilions hosted by participating countries, companies, and organizations showcase social and environmental challenges as well as technologies that help address them. As part of the Expo’s legacy, it is intended that these efforts will enhance the sustainability of companies and society entirely.
The author supports the Association’s sustainability initiatives in an external expert capacity, including as a member of the Sustainable Procurement Working Group and the Human Rights Working Group, and as a Grievance Mechanism Adviser. This article first introduces the sustainability initiatives at the Osaka Expo 2025 and then discusses their impact on corporate sustainability and legal practice, along with corresponding responses[3].
Ⅱ. Sustainability Initiatives at the Osaka Expo 2025
1. Sustainable Procurement Code
The Association has formulated a “Code of Sustainable Procurement” (hereinafter, the “Procurement Code”)[4] that sets sustainability standards that apply to all goods and services it procures, as well as all licensed products. Suppliers, licensees, and pavilion organizers, among others, are required to comply with the Procurement Code in the manufacturing, distribution, and other processes relating to the procured items, and to take appropriate measures to ensure that the Procurement Code is likewise observed throughout their supply chains.
The Procurement Code establishes cross-cutting requirements and expectations in the areas of environment, human rights, labor, and economy for all goods. In addition, it sets item-specific criteria for timber, paper, agricultural products, livestock products, fishery products, and palm oil.
While this framework builds on the procurement code introduced for the Tokyo 2020 Olympic and Paralympic Games (the “Tokyo 2020”)[5], the Expo’s Procurement Code advances sustainability in the following three ways:
(1) Clarifying the Expectation for Human Rights and Environmental Due Diligence (“HREDD”)
International standards such as the UN Guiding Principles on Business and Human Rights (the “UNGPs”) call on companies to carry out human rights due diligence to assess and address adverse human rights impacts across their supply chains. Recognizing the close interlinkage between human rights and the environment, the scope for due diligence has expanded to the area of environment as well.
Whereas the Tokyo 2020’s procurement code merely noted in a footnote that the human rights due diligence under the UNGPs could be a reference for compliance[6], the Osaka Expo 2025’s Procurement Code expressly states in the body text that as HREDD shall be referenced as precondition for establishing a compliance system, as follows:
“They (Suppliers, Licensees, and Pavilion Organizers) shall observe, in assessing and addressing the risks to sustainability, the due diligence required of them by the international guidelines, including the United Nations Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, OECD Due Diligence Guidance for Responsible Business Conduct, and ILO Tripartite Declaration of Principles Concerning Multinational Enterprises and Social Policy.”[7]
(2) Setting Item-Specific Criteria based on the HREDD Expectation
The item-specific criteria require due diligence, particularly upstream in the supply chain, not only of environmental conservation standards—e.g., forest conservation and biodiversity—but also of standards for respecting the human rights of indigenous peoples, local communities, and workers. These requirements also reflect the expectation for HREDD throughout the supply chain.
For items covered by specific certifications, the Code generally recognizes a high level of conformity (for example, in the timber criteria, certifications by the Forest Stewardship Council (FSC), the Programme for the Endorsement of Forest Certification (PEFC), and the Sustainable Green Ecosystem Council (SGEC)). However, certification is positioned only as a means to complement the implementation of HREDD through supply chains. Conformity may be acknowledged without certification if HREDD is conducted; conversely, even certified items may be deemed non-conforming where serious human rights or environmental risks are found.
(3) Strengthening and Diversifying Sustainability Criteria for Item-Specific Standards
For certain goods, the sustainability criteria are more stringent than those in the Tokyo 2020’s procurement code.
For example, in response to increased demands to safeguard biodiversity, the certifications for fishery products are limited to those recognized by the Global Sustainable Seafood Initiative (GSSI). The Code also expressly adopts a basic policy of refraining from the use of endangered species[8].
Furthermore, reflecting heightened expectations concerning animal welfare, the criteria for livestock products newly require that appropriate measures be taken—at the production stage—in line with the concept of animal welfare and with reference to the World Organisation for Animal Health (WOAH) Terrestrial Animal Health Code.
2. First Implementation of Human Rights Due Diligence at a World Expo
Acknowledging that the Expo’s theme—“Designing Future Society for Our Lives”—can only be realized if the rights of every person involved are respected, Expo 2025 is implementing human rights due diligence for the first time in the history of World Expos. While the Tokyo 2020 undertook advanced measures in sustainable procurement, issues also arose—such as the resignation of the organizing committee’s head following remarks that disregarded human rights, and bribery/corruption involving sponsors that escalated into criminal cases. In light of these lessons, the Expo recognized the need to assess and address human rights risks not only in procurement but across organizational operations as a whole.
The Association adopted a Human Rights Policy[9] as a foundation for human rights due diligence and established a Human Rights Working Group comprising diverse stakeholders—including human rights organizations, labor unions, and human rights experts—through whose input human rights due diligence is being carried out.
In identifying salient human rights issues, the Association is broadly evaluating impacts on various rights-holders across (i) the workplace and day-to-day operations, (ii) the Expo period and the Expo site, (iii) procurement and the supply chain, and (iv) media, advertising, and related activities. Notably, bribery and corruption are also positioned as one of the important human rights issues.
To investigate risks in greater detail, internal department-level questionnaires are being conducted. Regarding procurement and supply-chain risks, as part of implementing the Procurement Code, the Association collects suppliers’ pledges and checklists concerning the Code and conducts interviews with particularly high-risk business operators. During the Expo, on-site “SUS (Sustainability) Patrols” are also carried out to monitor whether any issues—such as human rights problems—are arising at the venue.
In addition, grievance mechanisms have been established to receive and address reports concerning human rights and related issues, as described below.
3. Strengthening Grievance Mechanisms for Addressing Sustainability Risks
To identify sustainability risks—such as those relating to human rights and the environment—and address them at an early stage, it is useful to put in place a grievance mechanism that listens to stakeholders and provides a means of redress.
Continuing from the Tokyo 2020, the Expo has set up a grievance mechanism to receive allegations of non-compliance with the Procurement Code and to respond under the supervision of an independent advisory panel; the status of case handling is made public[10]. To improve of initial screening and response process, the Association has newly introduced a “Grievance Mechanism Advisory Council”, which is made up of three external experts, and addresses grievances with its advice from the initial stage of process.
Moreover, with a view to receiving a broader range of human rights-related reports beyond procurement and the supply chain, a separate human rights reporting desk has been established, and its case-handling status is publicly disclosed[11].
4. Proactive Initiatives, Exhibits, and Events that Advance Sustainability
Beyond the above, the Association is undertaking various initiatives to enhance sustainability. For example, it is working to build an Event Sustainability Management System (ESMS) for Expo operations. From a climate-action perspective, it measures greenhouse-gas emissions across the entire supply chain (so-called “Scope 3”), sets reduction targets, works to reduce emissions, and encourages business partners to reduce theirs as well. From a circular-economy perspective, it measures outputs of various waste streams—including plastics—and pursues reduction and recycling.
Many Expo exhibits also relate to sustainability. By way of example, the “Blue Ocean Dome” pavilion[12] features exhibits on the sustainable use of marine resources and the protection of marine ecosystems toward realizing the “Osaka Blue Ocean Vision,” which aims to reduce additional pollution from marine plastic litter to zero by 2050. The Sumitomo Pavilion, presented by the Sumitomo Group, highlights the importance of forest conservation and introduces “Seeds of the Future,” a set of ideas and technologies that contribute to a sustainable future society[13]. The joint pavilion of Osaka Metropolitan University and the Iida Group features a distinctive exterior draped entirely in Nishijin brocade fabric under the name “Sustainable Möbius,” and showcases concepts for future housing and urban design that enhance people’s well-being and realize a decarbonized society[14]. The Expo site is also conducting demonstration tests of the “AI Suitcase,” a navigation robot designed for people with visual impairments[15].
In addition, the Expo has established “Theme Weeks” on eight topics—including Peace and Human Rights, the Earth’s Future and Biodiversity, and SDGs + Beyond—accompanied by related events for each theme[16].
Ⅲ. Expo’s Impacts on Sustainability & Legal Practice
The Osaka Expo 2025 has been operated with the intention of turning the knowledge and lessons gained through the various sustainability initiatives described above into a legacy that generates positive impacts for companies and society. Below, I analyze how these initiatives are expected to affect corporate sustainability and legal practice, and what responses are expected.
1. Expansion of Sustainable Procurement Practice
As expressly stated in “1. Purpose,” the Procurement Code aims to promote an expansion of initiatives similar to this Procurement Code to attain the SDGs and firmly establish a sustainability-oriented mindset in wider society, from the central and local governments which provide financial and other forms of support to planning and
organizing the Expo.
Spurred by the Expo, sustainable procurement practices are expected to advance further in both public and private procurement. Indeed, drawing on the legacy of the Tokyo 2020 Procurement Code, the Tokyo Metropolitan Government formulated the Tokyo Socially Responsible Procurement Guidelines[17] in 2024 and began implementing them from 2025 onward. The Government of Japan, which had already conducted environmentally conscious procurement under the Act on Promoting Green Procurement[18], also adopted a decision in 2023 on consideration for human rights in public procurement, requesting that efforts to respect human rights be required in bid specifications, contracts, and the like[19]. Moreover, in the outline for the 2025 revision of Japan’s National Action Plan on Business and Human Rights[20], respect for human rights in public contracts—including public procurement and subsidized projects—is positioned as one of the priority areas.
This evolution in practice can raise incentives and motivation for companies to advance human rights and environmental initiatives, as such companies will be selected and rewarded by procuring entities and client companies. Conversely, failure to meet purchasers’ and clients’ expectations creates risks that can hinder business relationships. For sustainability & legal managers and professionals, it is becoming even more important, beyond merely complying with applicable laws, to accurately understand the sustainability requirements and expectations likely to be imposed by purchasers and client companies—such as those set out in the Expo’s Procurement Code—to respond to them, and to proactively disclose the company’s own initiatives, in order both to manage risks and to realize opportunities.
2. Heightened Calls to Strengthen Corporate HREDD Practices
As noted above, the Expo’s Procurement Code clearly incorporates the implementation of HREDD as an expectation and request of suppliers and other companies; the Association is also taking the lead by implementing human rights due diligence at a World Expo for the first time.
In 2022, the Government of Japan published the Guidelines on Respecting Human Rights in Responsible Supply Chains[21], calling on Japanese companies to implement human rights due diligence. On the environmental side, in 2023 it issued a Handbook on Environmental Due Diligence, among other measures, to support Japanese companies’ environmental due diligence efforts.
In Europe and Northern America, regulations requiring the implementation and disclosure of HREDD, as well as trade restrictions and other measures, have been introduced and strengthened. Entering 2025, however, “anti-ESG” and “anti-DEI” have become political movements under the U.S. Trump administration, and signs of stagnation are also evident in EU policies related to sustainability due diligence and disclosures. Precisely because such uncertainty has arisen in the West, the Osaka Expo 2025 presents an opportunity for Japanese and Asian companies to take the lead on HREDD and attract attention. Legal & sustainability managers and professionals are expected to implement such due diligence steadily—drawing on the initiatives being carried out at the Expo—and to disclose those efforts.
3. Heightened Calls to Strengthen Corporate Grievance Mechanisms
As described above, the Association operates multilayered grievance mechanisms, including a reporting channel for non-compliance with the Procurement Code and a separate channel for human rights-related reports, to address complaints from diverse stakeholders.
The Procurement Code also expressly requests that suppliers and other companies endeavor to establish grievance mechanisms to receive and respond to reports of legal violations, Procurement Code breaches, and the like, as one of the sustainability criteria.
Many companies have established internal whistleblowing desks and systems to comply with the Whistleblower Protection Act, and consultation desks and systems from the standpoint of preventing harassment. However, as noted, international standards such as the UN Guiding Principles call for effective grievance mechanisms capable of addressing a broader range of grievances including human rights and environmental issues from more diverse stakeholders. The UN Guiding Principles set out eight effectiveness criteria: (1) legitimacy, (2) accessibility, (3) predictability, (4) equity (fairness), (5) transparency, (6) rights-compatibility, (7) a source of continuous learning, and (8) based on engagement and dialogue. When developing grievance mechanisms, companies should review existing systems against these criteria and consider whether channels and structures need to be improved or added.
Establishing effective grievance mechanisms enables early identification of risks and timely responses by listening to stakeholder voices. Legal & sustainability managers and professionals are expected to develop and enhance grievance mechanisms, taking into account the Expo’s initiatives and lessons learned.
4. Heightened Expectations for Technologies and Businesses that Solve Social and Environmental Problems
As the Expo’s many exhibits demonstrate, there are high expectations that diverse technologies and business models contributing to solutions for social and environmental challenges will be created through innovation.
legal & sustainability managers and professionals are expected to accompany and support companies as they develop new technologies and bring them to market.
To that end, it is important—through dialogue with stakeholders—to visualize what social and environmental issues exist in relation to the company’s business, and what impact the company’s technologies and businesses can have in solving those issues. Supporting initiatives and disclosures aligned with sustainability-related rules can increase the company’s appeal to customers and investors, potentially leading to business opportunities and access to finance. In 2024, Japan’s Financial Services Agency (FSA) also formulated Basic Guidelines on Impact Investing (Impact Finance)[22]—which aims to achieve both social/environmental effects and investment returns—and is promoting it.
IV. Conclusion — Potential and Challenges for Legal Professionals
Legal professionals can play a very significant role in realizing the sustainable future society envisioned by the Expo. As noted, progress in corporate legal and sustainability practice is particularly anticipated as a legacy of the Osak Expo 2025. With respect to sustainable procurement, the strengthening of HREDD, and the establishment of grievance mechanisms, legal professionals—who have expertise and experience in rule analysis, design, and operation, as well as in fact-finding and dispute resolution—can contribute in many ways. I have personally come to appreciate the potential to contribute through my experience supporting initiatives at the Osaka Expo 2025.
At the same time, to genuinely promote corporate initiatives that advance sustainability and to support the realization of innovations that help solve social and environmental challenges, we legal professionals may need to continuously improve sustainability-related legal practice through dialogue and collaboration with a wide range of stakeholders. I hope that many readers, through the Osaka Expo 2025, will reflect on a sustainable future society and find an opportunity to consider their own roles and challenges.
[1] https://www.expo2025.or.jp/en/overview/
[2] https://www.expo2025.or.jp/en/overview/sustainability/
[3] Please note that the contents of this article are based on the author’s personal views informed by his own experience and do not represent the opinions of any affiliated or related organizations
[6] See footnote iv of the Tokyo 2020 Procurement Code.
[7] See 5(3) Development of a system for Procurement Code compliance of the Procurement Code.
[8] Products subject to sustainable use measures such as conservation of resources and securing regeneration, or those derived from full aquaculture, may be used.
[9] https://www.expo2025.or.jp/wp/wp-content/uploads/EN_Human-Rights-Policy-.pdf
[11] https://www.expo2025.or.jp/en/news/news-20250311-02/
[12] https://www.expo2025.or.jp/en/domestic-pv/zeri/
[13] https://sumitomoexpo.com/en/
[14] https://www.ighd.co.jp/en/lp/contents.html
[15] https://www.omron.com/global/en/media/2025/04/c0411.html
[16] https://theme-weeks.expo2025.or.jp/en/
[17] https://www.zaimu.metro.tokyo.lg.jp/documents/d/zaimu/20250411_SR_shishin_englishver
[18] https://www.env.go.jp/content/000067260.pdf
[19] https://www.cas.go.jp/jp/seisaku/business_jinken/dai7/siryou4.pdf
[20] https://www.cas.go.jp/jp/seisaku/business_jinken/dai11/kosshian.pdf
[21] https://www.meti.go.jp/policy/economy/business-jinken/guidelines/provisionalenglishtranslation.pdf
[22] https://www.fsa.go.jp/singi/impact/siryou/20240329/02.pdf
[Author Information]
Daisuke Takahashi
Partner, Shinwa Law / Steering Committee Officer, BHR Lawyers Network Japan
Daisuke is advising multinational corporations on global legal compliance, sustainability/ESG, and technology issues.
For the Osaka Expo 2025, he serves as a member of the Sustainable Procurement Working Group and the Human Rights Working Group, and as a Grievance Mechanism Adviser.
Daisuke has also served as Chair of CSR Project Team of Japan Federation of Bar Associations (JFBA); Co-Chair of BHR Committee of International Bar Association (IBA); Consultant for OECD Centre for Responsible Business Conduct; Member of Working Group on the National Action Plan on BHR of the Japanese Government; Representative Director of the Japan Center for Engagement and Remedy on BHR (JaCER); and Alternate Legal Expert for OEIGWG on TNCs and OBEs under UN Human Rights Council.