The E.U.’s Corporate Sustainability Due Diligence Directive (CSDDD) – human rights violation reporting legislation targeting corporate sustainability due diligence – was introduced in July 2024, but the rollout was delayed and it has yet to come into force.
Still, experts warn that the CSDDD regulations are coming, and importers need to eliminate any forced labor from their supply chains or risk having their products pulled from the E.U. market.
At a panel during Seafood Expo Global/Seafood Processing Global, which took place in Barcelona, Spain from 21-23 April, leaders from the Consumer Goods Forum, UL Solutions, Global Seafood Alliance, and ASPCA spoke about the importance of audits to root out labor violations and the need for companies to ensure proper labor protections are in place.
“CSDDD has had a little bit of a tumultuous 2025 [...] it was adopted and then it was reopened for renegotiation, but I’m pleased to say for those who don’t know yet, we do have a final text as of February of [2026]. CSDDD essentially requires companies in a scope to do seven activities in order to conduct human rights due diligence,” UL Solutions Head of Advisory Services Daphne Guelker said. “Member states are required to now transpose this legislation into member state laws by July 2028.”
Once the laws are in place, any part or component of a product that was made with forced labor will be prohibited from the E.U. market, Guelker said. Guelker added that forced labor import bans already exist in the U.S., Canada, and Mexico. With this legal framework, local authorities can start a pre-investigation when they receive a complaint or if they have a suspicion that a product has been made with forced labor. If there’s reasonable suspicion, they can go on to a formal investigation and can be potentially withdrawn from the E.U. market.
The forced labor regulation legislation will go into effect late 2027.
Initially, 7,500 E.U. companies were subject to the measures, with the legislation targeting companies with a global turnover of more than EUR 1.5 million (USD 1.7 million) and that employ more than 5,000 people. The framework was revised to target 1,000 companies, Guelker said. However, the rules will have a ripple effect far beyond the companies that directly fall under CSDDD.
“No matter how big you are, in the end, all of this will affect you because either a company that you could sell to will actually have to cascade down some of those requirements and make sure that they practice corporate due diligence, but overall nobody’s immune to the possibility of an allegation of false labor, leading to an investigation from the E.U. or a relevant member state authority,” The Consumer Goods Forum Director of Sustainability Didier Bergeret said. “I think overall we’re talking about 38 fundamental human rights; most certification will typically cover only 10 to 12 because we’re talking about labor rights.”
Given the stakes involved, social audits and third-party verification of audits are an important tool for detecting and addressing labor violations.
Portsmouth, New Hampshire, U.S.A.-based nongovernmental organization Global Seafood Alliance (GSA) Director of Social Responsibility Amy McGann said that the organization uses both Best Aquaculture Practices (BAP), Best Seafood Practices (BSP), and enhanced social audits. GSA works with six certification bodies in-house, and once audits are completed, GSA has an additional technical desk review of audits, and requires every shift to be audited.
“If a company chooses to use audits, that doesn’t mean that it obviates their responsibility to work on other issues such as responsible purchasing practices or the need to promote and protect the right to freedom of association and collective bargaining which is the enabling right for workers,” McGann said.
The Association of Professional Social Compliance Auditors (APSCA) Director of External Affairs Karina Ufert added that social audits are vital to finding true labor irregularities, because employees need to feel comfortable opening up about workplace violations.
“We from ASPCA from the professional association side, we put the focus on the people to go into the field ... it’s a profession that requires a very specific skill set,” Ufert said. “It’s very small, but also contextual awareness, because not every single person can make a worker feel comfortable and tell their story.”
It’s an ongoing process, and one that Guelker said needs to be ongoing and integrative.
“It’s not about getting it right the first time. It’s about doing it again, and again, and again, and improving each and every time that we do it,” Guelker said. “It’s not a one-off project, it’s not a sustainability initiative, it’s not a pilot, it’s changing the way we do business.”
In February, Europêche, Europe’s fishing industry representative body, praised the European Commission for completing an omnibus package streamlining forthcoming regulations, including CSDDD.
"The package marks a significant first step towards addressing longstanding concerns about regulatory complexity and administrative burdens,” Europêche said in a release. “The fishing sector urges the Commission to go further and conduct a comprehensive review of fisheries and environmental policies to improve competitiveness while maintaining sustainability goals.”
