What CSDDD asks of manufacturers and their suppliers

What the CSDDD asks of very large companies, what it may ask of manufacturers in their chains, and where product-level records fit.

By Jack Cook 10 February 2025
ESG Supply Chain

The Corporate Sustainability Due Diligence Directive (CSDDD), Directive (EU) 2024/1760, sets a due diligence duty for very large companies. The Commission describes it as requiring companies to "identify and address actual and potential adverse human rights and environmental impacts" in their own operations, their subsidiaries and their chains of activities.

Who it applies to

Scope depends on company size and turnover. The thresholds are the subject of the EU's simplification package, so check the Commission's CSDDD page for the current position.

Application dates

The Commission's CSDDD page describes the Directive as amended by the simplification package, and gives these dates: Member States must transpose the Directive by 26 July 2028 and apply the rules from 26 July 2029. Reporting under Article 16 applies for financial years starting on or after 1 January 2030. Check the Commission's CSDDD page before relying on these dates.

What it may mean for a manufacturer

The Directive is aimed at the company that carries the due diligence duty. A manufacturer in that company's chain may be asked to show how the impacts it describes are identified and managed. Evidence for the chain of activities can be requested at two levels:

  • Product level: the materials, components and processes behind a specific product or batch, with the certificates and test results that show them.
  • Supplier level: who supplied each material or part, and what those suppliers have confirmed about their own practices.

What to do now

  • Ask your larger customers which due diligence evidence they expect from you, and in what format.
  • Keep certificates and test results against the product and batch they relate to, not in a separate folder.
  • Keep a current list of your suppliers, with the declarations each has given you and the dates.

Where product records fit

Due diligence is only as credible as the records behind it. Those records often sit in different places: certificates in a quality folder, batch results in a spreadsheet, supplier declarations in an inbox. Holding them against the product and the batch makes them quicker to find, and easier to check when a customer or auditor asks. When a request does arrive, the faster answer is a record that already exists for that product and batch, rather than a search through several places.

TraceID's Traced module keeps a product's certificates and batch records in one place, which is the raw material for this kind of evidence.

Where to read more

The Commission's page on corporate sustainability due diligence sets out the current position: Corporate sustainability due diligence (European Commission).

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