Supply chain due diligence legislation of the European Union: Legal effect
According to Article 38 (Legal Effect), the CSDDD Directive officially enters into force on July 25, 2024.
However, as noted, this EU Directive does not apply directly to EU organizations or individuals but establishes the fundamental, core framework of supply chain due diligence obligations for Member States to implement through national legislation, applicable to companies within their territory. Accordingly, the Directive also sets out corresponding effective dates for these provisions.
Specifically, under Article 37 of the Directive:
- EU Member States must, no later than 26 July 2026, draft and adopt national legislation to concretize the principles of this Directive for implementation within their territory.
- Regulated companies will then begin to implement due diligence obligations under national law in successive groups on 26 July 2027, 26 July 2028, or 26 July 2029 (with the largest companies starting first, followed by smaller-scale companies).
Note: In February 2025, the European Commission issued two proposals to amend the Directive, aiming to reduce certain requirements and postpone practical implementation. These proposals are still under consideration and have not been adopted; therefore, the provisions of the Directive remain in force according to the schedule above. Nevertheless, even if these proposed amendments are adopted, most of the core content of the Directive will remain unchanged, with no significant modifications.
Source: Compiled by the TTWTO-VCCI Research Group