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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, Trilogue 12/2025) 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 2026.
  • In Germany, transposition is expected through an amendment of the LkSG or the introduction of a complementary law (DDG).
  • Currently under discussion: the European Commission's Omnibus proposal (February 2025) to simplify and postpone individual CSDDD obligations.

Phased application from 2027

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 (Trilogue 12/2025, 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 plan: obligation to draw up a plan to limit global warming to 1.5 degrees with targets to 2050.

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 of at least 5 percent of worldwide net turnover.
  • Publication of infringements (naming and shaming).
  • Exclusion from public procurement.
  • Civil liability towards damaged parties for intentional or negligent breach of due diligence - with damages claim.
  • Right of action also for damaged parties from non-EU countries before EU courts, limitation period at least 5 years.
  • Unlike LkSG: explicit civil liability of companies directly towards damaged parties.

Relationship between CSDDD and LkSG

  • LkSG has been German law since 2023; CSDDD takes effect through national transposition.
  • CSDDD goes further on several points: chain of activities instead of supply chain, lower thresholds (1,000 employees + turnover instead of 1,000 employees), civil liability.
  • The climate plan is new in CSDDD and not contained in LkSG.
  • German implementation will likely amend the LkSG or replace it with a new law (DDG).
  • 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: 02828 9039920

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 the Omnibus I trilogue (12/2025). 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.
You are liable directly towards damaged parties if you intentionally or negligently breach due diligence and damage results - damages claim before EU courts, limitation period at least five years. LkSG does not carry this explicit liability basis. 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.
As a CSDDD-bound company you draw up a plan to limit global warming to 1.5 degrees in line with the Paris Agreement, with reduction targets to 2050 and - where relevant - milestone targets to 2030 in 5-year steps. The plan is part of your risk management and must be reported publicly. We deliver from the customs data inputs on transport- and origin-related emission factors that you need for CBAM anyway - collected once, used twice in both regimes.
CSDDD becomes effective on 26 July 2029 - uniformly, no pre-stage. The national transposition deadline is 26 July 2028 (extended by Omnibus I); Germany will likely amend the LkSG or replace it with a new DDG. The originally planned earlier phases from 2027 and 2028 were dropped by the Omnibus I trilogue (12/2025). 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.