Updated 20 October 2026. The EU Corporate Sustainability Due Diligence Directive (CSDDD) does not automatically apply to every apparel brand or factory selling into Europe. Following the Omnibus I amendments, its direct obligations target very large companies that meet specified thresholds. Smaller suppliers can still receive information requests from covered customers, but being part of a large brand’s supply chain does not itself make a small garment factory a company directly regulated by the directive.
The most useful starting point is to distinguish legal scope, application dates and commercial expectations. The first two follow the directive and national implementation; the third depends on customer relationships and risk-based purchasing decisions.
What is the CSDDD?
The CSDDD is Directive (EU) 2024/1760, which entered into force on 25 July 2024. It establishes a due diligence framework for large companies to identify and address actual and potential adverse human-rights and environmental impacts in their own operations, subsidiaries and relevant chains of activities. It is not a product certificate, a textile-specific standard or a requirement that every supplier hold a new EU licence.
The directive has been changed by the Omnibus I simplification package, including Directive (EU) 2025/794 and Directive (EU) 2026/470. Reading only the original 2024 text or an older news article can produce the wrong thresholds and deadlines. The European Commission’s updated CSDDD overview sets out the current position.
Which apparel companies fall directly within scope?
The amended general thresholds distinguish companies established in the EU from companies established outside it. They are not based on the apparel industry as such.
| Company type | General scope test after Omnibus I | What this means for apparel |
|---|---|---|
| Large EU company | More than 5,000 employees on average and more than €1.5 billion in worldwide net turnover, subject to the directive’s detailed group and calculation rules. | A very large EU-headquartered apparel group may be directly covered if the applicable tests are met. |
| Large non-EU company | More than €1.5 billion in net turnover generated in the EU, subject to the detailed scope rules. | A non-EU fashion group with substantial EU sales may be covered even without EU headquarters. |
| Small or medium-sized supplier | Not directly covered merely because it sells to an EU brand. | It may receive proportionate information requests through a covered customer’s due diligence process. |
Ultimate parent companies, group consolidation, franchising and licensing arrangements have additional rules. The thresholds in the table are a screening summary, not a substitute for assessing a specific corporate structure. The Commission notes that franchising and licensing can bring some arrangements into scope where their separate royalty and turnover criteria are met.
Does the directive apply to a factory in China, Bangladesh or Türkiye?
Location alone does not settle the question. A garment factory outside the EU with turnover below the non-EU threshold will generally not be directly covered just because it supplies an EU retailer. Yet a covered retailer may need to understand risks in its production chain, including the conditions under which garments are made. That can lead to requests for factory identity, subcontracting details, working conditions, remediation records and information about specific sourcing risks.
It is important to separate those requests from legal obligations imposed directly on the supplier. A buyer should explain why it needs information and avoid treating every request as if it were a mandatory EU filing. Our article on supplier due diligence and follow-up questions covers the practical information exchange.
What changed under Omnibus I?
The 2025 and 2026 amendments simplified and delayed parts of the original framework. For apparel procurement teams, three changes are especially important: the direct scope now focuses on much larger companies; the timetable has moved; and the due diligence approach is designed to prioritise areas where adverse impacts are most likely and severe, using reasonably available information.
The revised approach does not mean a company may ignore credible reports of harm. It means due diligence is intended to be risk-based rather than an exercise in demanding identical paperwork from every small supplier. The European Commission also highlights protections and support for smaller business partners, including limits on information requests and forthcoming model contractual clauses.
When will the CSDDD apply?
| Date | Milestone |
|---|---|
| 25 July 2024 | Original CSDDD entered into force. |
| 26 February 2026 | Directive (EU) 2026/470 was published in the Official Journal, introducing substantive Omnibus I amendments. |
| 26 July 2028 | Member States must adopt and publish the required national transposition measures. |
| 26 July 2029 | Amended CSDDD national measures are to apply to companies within scope. |
| Financial years starting on or after 1 January 2030 | Separate timing for the directive’s Article 16 reporting measures, as stated in the Commission’s updated guidance. |
The distinction between transposition and application matters. A directive requires Member States to enact national measures, and national enforcement details may differ within the permitted EU framework. The Commission expects main guidelines by 26 July 2027 and further guidance by 26 July 2028. Companies should track those materials instead of treating the 2024 version as the final compliance manual.
What must a company within scope actually do?
At a high level, the CSDDD requires a due diligence process for adverse human-rights and environmental impacts. Depending on the facts and the amended legal requirements, this includes integrating due diligence into policies and risk management, identifying and assessing impacts, taking appropriate measures to prevent or mitigate potential harm and address actual harm, providing complaint and notification channels, monitoring effectiveness and communicating on the process.
For an apparel group, the relevant questions may concern working hours, recruitment practices, subcontracting, workplace safety, chemical handling or environmental impacts in particular parts of the supply chain. These are examples of possible risk areas, not findings about a named factory. The appropriate response depends on severity, likelihood, the company’s relationship to the impact and what information is reasonably available.
An audit report can contribute evidence but does not necessarily complete due diligence. Audits capture a point in time; a responsible system must also address follow-up, corrective action and changing production conditions. See why a factory audit is not the same as due diligence and how purchasing practices create supplier risk.
What could apparel suppliers be asked to provide?
A covered buyer may seek evidence that is relevant to a particular identified risk. Requests should be proportionate, understandable and capable of verification. Useful categories include:
- Factory identity and operations: legal names, addresses, production activities and the use of approved or unapproved subcontractors.
- Employment practices: recruitment procedures, working-hours records, grievance channels and documented corrective actions where relevant.
- Material sourcing: origin and supplier records for inputs linked to a specific concern, with an explanation of any traceability gaps.
- Environmental controls: permits, testing and management records where a material process presents a relevant risk.
- Follow-up: named responsible staff, actions, deadlines, supporting records and evidence of whether a problem was resolved.
A supplier can respond more effectively by maintaining an organised, current record set than by collecting unrelated certificates. Buyers should identify the question each document is meant to answer. For the underlying distinction, see supply-chain traceability records.
How are penalties and liability handled?
The Commission describes enforcement through national supervisory authorities and civil liability under national law. For the most serious violations, the amended directive sets a maximum limit for pecuniary penalties at 3% of a company’s net worldwide turnover. This is not a fixed fine automatically imposed on every breach, and it should not be confused with a charge against every supplier in a covered company’s supply chain.
Liability depends on the applicable national law and the facts. Affected persons may have a right to full compensation where a company is found liable under national rules. Procurement teams should therefore avoid presenting compliance as a certificate that removes all possible responsibility.
What should brands and suppliers do in 2026?
- Screen legal scope first. Confirm company location, turnover, employee count and relevant group structure against the amended thresholds.
- Separate law from contract. Identify which requests follow a covered company’s due diligence programme and which obligations directly apply to the supplier.
- Prioritise actual risks. Focus on material production stages and credible concerns rather than sending the same checklist to every factory.
- Keep records usable. Make documents current, traceable to a facility or order, and understandable without a lengthy verbal explanation.
- Track implementation. Review Commission guidance and the national transposition measures before the 2029 application date.
The central distinction is that direct CSDDD coverage is narrow, while the practical effects of due diligence can extend through commercial supply chains. Apparel buyers should not overstate the legal scope, and suppliers should not dismiss a legitimate, risk-specific information request merely because they are outside the direct thresholds.
Primary sources and editorial note
- European Commission, updated Corporate Sustainability Due Diligence overview.
- Directive (EU) 2024/1760, original CSDDD.
- Directive (EU) 2025/794, postponement amendments.
- Directive (EU) 2026/470, Omnibus I substantive amendments.
Editorial scope: This independent article describes EU-level rules as of 20 October 2026. It is not legal advice. National implementation and subsequent Commission guidance should be checked for specific compliance decisions.
