The creation of the "Transposition Guide for the Corporate Sustainability Due Diligence Directive (CSDDD)" is the result of collaboration between CCC, European Coalition for Corporate Justice (ECCJ), European Centre for Constitutional and Human Rights (ECCHR), Frank Bold, Oxfam, CIDSE, FIDH, Anti-Slavery International, and Friends of the Earth Europe.
The guide is aimed at assisting civil society organisations (CSOs), trade unions, activists, and other stakeholders in advocating for a robust and inclusive transposition process across EU Member States. CSOs are encouraged to use the guide as a tool to engage in the transposition process.
It aims to ensure that the CSDDD is implemented in a way that promotes meaningful change, improves protections for vulnerable workers and communities, and holds companies accountable for human rights violations and environmental harm throughout their supply chains.
The transposition of the directive into national law is set to occur by July 2026, after its publication in the EU’s Official Journal in June 2024. This two-year period provides a window of opportunity for CSOs to influence the final shape of the directive at the national level.
The CSDDD, adopted by the EU in April 2024, marks a significant first step toward creating more responsible global supply chains, free from human rights violations, labour abuses, and environmental damage.
However, while the directive holds the potential to improve corporate accountability, it has several notable limitations.
The current scope of the directive is limited in terms of the number of companies it applies to, and it does not include some essential provisions, such as key International Labour Organization (ILO) conventions related to occupational safety and health.
Moreover, the obligations within the value chain are somewhat restricted, which could hinder its full impact on protecting workers and communities globally.
The guide identifies several key priorities for the transposition process, including:
Access to Justice: The guide emphasises the importance of ensuring effective access to justice for affected individuals and communities. This includes reversing the burden of proof in civil claims to make it easier for victims to hold companies accountable, as well as setting practical time limitations for legal proceedings.
Stakeholder Engagement: Meaningful and continuous engagement with stakeholders, particularly those directly affected by corporate activities, should be at the core of the due diligence process. This engagement must begin early and be ongoing, enabling affected communities, workers, and other stakeholders to have a genuine influence on corporate decisions.
Broader Scope of Personal and Material Coverage: The guide advocates for the expansion of the personal scope to include more companies and stakeholders, and for removing any conditions that limit the material scope of the directive. It also calls for aligning the environmental scope with internationally recognised standards, to ensure that companies are held accountable for their environmental impacts.
Comprehensive Due Diligence Obligations: The guide stresses the need to extend due diligence requirements to all parts of the value chain, including the downstream activities of financial services, which can play a critical role in financing and enabling harmful practices.
