Skip to content

CSDDD EU Due Diligence from 2029

We deliver the customs-relevant CSDDD data stream for your due diligence obligations from 26 July 2029. You send us your tier-1 supplier list and CN codes; we link your supplier master data to customs clearance and hand structured foreign trade data to your CSDDD officer for risk analysis and reporting. The threshold of 5,000 employees and EUR 1.5 billion net turnover worldwide (Omnibus I, Directive (EU) 2026/470) decides whether you are in scope - we start the data work in parallel with LkSG.

What it is about

You carry accountability for CSDDD as the in-house compliance function - we are your operational data supplier at the customs interface. The directive requires due diligence across the entire chain of activities: upstream to raw-material extraction, partly downstream covering distribution, transport and storage. We deliver the customs-relevant supplier, origin and goods-flow data directly from ongoing foreign trade operations - no break, no duplicate maintenance. You identify, assess and report; we make sure your data base is clean enough to support it.

Legal framework and 2026 status

  • Directive (EU) 2024/1760 of 13 June 2024 on corporate sustainability due diligence.
  • Publication in the Official Journal of the EU on 5 July 2024.
  • Entry into force on 25 July 2024.
  • Deadline for transposition into national law: 26 July 2028 (originally 26 July 2026; postponed by Directives (EU) 2025/794 and (EU) 2026/470).
  • Until transposition into German law, the LkSG applies in Germany.
  • Adopted: Omnibus I Directive (EU) 2026/470 of 24 February 2026, in force since 18 March 2026 - it simplifies and postpones CSDDD obligations.

Application from 26 July 2029

PhaseApplication fromThresholds
Application from 26 July 202926 July 2029EU companies with more than 5,000 employees worldwide and net turnover above EUR 1.5 billion worldwide. Non-EU companies with net turnover above EUR 1.5 billion in the EU (no employee threshold for non-EU companies, only the EUR 1.5 billion EU net turnover threshold). Note: under Omnibus I (Directive (EU) 2026/470, entry into force 18.3.2026) the original three phases were dropped and consolidated into a single application date of 26 July 2029, with only one threshold (5,000 employees + EUR 1.5 billion net turnover).

Obligations under CSDDD

  • Integration of due diligence into corporate policy and risk management.
  • Identification and assessment of actual and potential adverse impacts on human rights and the environment along the chain of activities.
  • Preventive measures to avoid adverse impacts, including contractual assurances and audits.
  • Cessation or mitigation of actual adverse impacts.
  • Complaint mechanisms for affected persons and stakeholders.
  • Monitoring of due diligence measures and their effectiveness.
  • Public reporting on due diligence (typically integrated into the CSRD sustainability report).
  • Climate transition plan: the obligation originally provided for (Art. 22) was deleted by Directive (EU) 2026/470.

Scope of the value chain

In customs clearance we see suppliers, countries of origin, transit countries and goods flows - exactly the upstream data that feeds into your CSDDD risk analysis. We also pass on downstream movements (distribution, transport, storage) that we handle, in structured form. End consumers and disposal phases remain outside scope. Where LkSG logic ends today - your own business area and direct suppliers - we continue delivering the data base to the raw-material stage, as far as it is reconstructable from customs operations.

Sanctions and civil liability

  • Fines from supervisory authorities capped at 3 percent of worldwide net turnover (Art. 27(4) as amended by Directive (EU) 2026/470).
  • Publication of infringements (naming and shaming).
  • Compliance with CSDDD obligations may be taken into account as an award criterion for public and concession contracts (Art. 31).
  • Civil liability follows national law; where a company is held liable, injured parties have a right to full compensation (Art. 29(2)).
  • Limitation period for damages actions at least 5 years (Art. 29(3)).
  • The uniform EU-wide liability basis of the original version (Art. 29(1)) was deleted by Directive (EU) 2026/470.

Relationship between CSDDD and LkSG

  • LkSG has been German law since 2023; CSDDD takes effect through national transposition.
  • CSDDD differs on several points: chain of activities instead of supply chain; its threshold (5,000 employees and EUR 1.5 billion net turnover) is well above the LkSG threshold (1,000 employees in Germany).
  • The climate transition plan originally provided for (Art. 22) was deleted by Directive (EU) 2026/470; LkSG does not contain one either.
  • German transposition must be adopted by 26 July 2028 and applied from 26 July 2029.
  • Until transposition, LkSG remains in force - parallel preparation for CSDDD makes sense to avoid duplicated work.

Connection to customs and logistics processes

We are not ourselves an addressee of CSDDD - we are your operational partner at the customs interface. We extract from every ATLAS declaration, every import and export operation the data that belongs in your CSDDD risk analysis: supplier, country of production, transit country, CN code, goods flow. We deliver this to you in structured form at the granularity the directive requires. You give us the additional compliance attributes (high-risk classification, supplier certificates, critical product groups); we maintain them inside the customs workflow so your CSDDD report and your customs clearance are fed from a single source.

How we support you

  • Provision of structured foreign trade data for CSDDD risk analyses.
  • Mapping between suppliers, CN codes, countries of origin and risk indicators.
  • Optional capture of additional compliance attributes (high-risk countries, critical product groups, supplier certificates) in the customs workflow.
  • Interfaces between customs systems (ATLAS) and customers' ESG / compliance tools.
  • Tracking of national CSDDD implementation and adjustment of data models when needed.
  • Cooperation with customers' compliance, sustainability and procurement teams.
Request CSDDD advice Talk to us: 02822 7133520

Frequently asked questions

You are in scope from 26 July 2029 if you are an EU company with more than 5,000 employees worldwide and more than EUR 1.5 billion net turnover worldwide - or a non-EU company with more than EUR 1.5 billion net turnover in the EU (no employee threshold for non-EU). The originally phased thresholds at 3,000 and 1,000 employees were dropped by Omnibus I Directive (EU) 2026/470. Member-state transposition runs until 26 July 2028. If you are unsure whether your group structure stays below the threshold: we check the customs and foreign trade side together with your compliance team.
The practical difference is data depth. The LkSG supply chain ends at your direct suppliers; indirect ones only come into scope on cause. The CSDDD chain of activities reaches upstream to the raw-material stage and covers downstream distribution, transport and storage. We deliver from customs clearance the data that maps this extended depth: country of origin, sub-suppliers from preference calculations, transit routes, warehouse movements. You get more coverage without building a separate data pipeline.
Directive (EU) 2026/470 deleted the originally uniform EU-wide liability basis; whether and how a company is liable follows national law. Where it is held liable, injured parties have a right to full compensation, and the limitation period is at least five years. For us that means one thing: we document every supplier and origin attribute inside customs clearance in a form that remains evidenceable in a dispute. You receive an audit-proof data trail, not just a data feed.
The obligation originally provided for in Art. 22 to draw up a plan to limit global warming to 1.5 degrees was deleted by Directive (EU) 2026/470. Companies in scope of CSDDD therefore no longer have this obligation. From the customs data we continue to deliver origin and goods-flow data that you need for CBAM anyway - collected once, used twice.
CSDDD becomes effective on 26 July 2029 - uniformly, no pre-stage. The national transposition deadline is 26 July 2028 (extended by Omnibus I). The originally planned earlier phases from 2027 and 2028 were dropped by Omnibus I Directive (EU) 2026/470. Until then LkSG remains in force for you - we already build the data base today so it supports both regimes from day one.
Substantively no - on the data side yes. CBAM is your CO2 pricing instrument with certificate purchase for imports such as iron, steel, aluminium, cement, fertilisers, hydrogen and electricity. CSDDD is your due diligence directive. Supplier, country of production and product group are needed in both regimes. We maintain these master data once, cleanly, inside customs clearance and feed them into your CBAM and CSDDD reporting in parallel - that is where you eliminate duplicated work.

Web design and search engine optimisation by Klickweise