regulations

CSDDD and DPP: Why Supply Chain Mapping Supports DPP Readiness

How the CSDDD forces companies to map their supply chain — and why this creates a critical data layer for the Digital Product Passport.

3/23/2026 · 6 min read · InfoDPP

What Is the CSDDD?

The Corporate Sustainability Due Diligence Directive (CSDDD), Directive (EU) 2024/1760, requires large companies operating in the EU to identify, prevent, and mitigate negative human rights and environmental impacts across their global value chains. In practice, this means companies must audit their suppliers and precisely map the flow of their raw materials.

Following the recent Omnibus I amendment (Directive (EU) 2026/470), the timeline was unified and the obligations now apply from 26 July 2029. The same amendment significantly raised the size thresholds:

EU companies are in scope only if they have more than 5,000 employees on average and worldwide net turnover above €1.5 billion (Article 2(1) CSDDD as amended).
Non-EU companies are in scope when they generated net turnover in the European Union above €1.5 billion in the financial year preceding the last completed financial year (Article 2(2) CSDDD as amended). The employee test does not apply.
A separate path keeps in scope EU and non-EU companies that entered into franchising or licensing agreements in the EU with more than €75 million in royalties and more than €275 million in turnover (worldwide for EU companies, in the EU for non-EU companies).

What This Is Not

The CSDDD is not a product-level regulation like the Digital Product Passport.

It does not require a QR code or data carrier on individual products
It does not sit inside the ESPR (Ecodesign for Sustainable Products Regulation) framework
It targets corporate diligence and the overall “chain of activities”, rather than the technical composition of a single item

Why It Matters for DPP Readiness

Even though CSDDD and ESPR are separate legal frameworks, their practical data dependencies overlap significantly:

1. Supplier mapping overlaps strongly

Future DPP delegated acts will likely require facility information, supplier names, and origin evidence. CSDDD can act as a strong legal driver pushing companies to finally map these supply chain tiers. The list of suppliers mapped for CSDDD can form a critical part of the evidence base needed to populate parts of a product’s history in a DPP, but not the whole product-level dataset.

2. Environmental footprints need primary data

CSDDD requires companies to assess their environmental impacts. Gathering primary data from suppliers to satisfy CSDDD creates the structural data backbone needed for future product-level sustainability reporting under ESPR.

3. The amendment limits how data flows down the chain

Even when a company falls in scope of the CSDDD, the Omnibus I amendment narrows what it can ask its business partners. Information may be requested from business partners with more than 5,000 employees only when it is necessary to comply with due diligence obligations. From business partners with fewer than 5,000 employees, information may be requested only when, based on reasonable judgement, it cannot be obtained by other means (Article 8(2a) CSDDD as amended). In addition, in-scope companies should, where reasonable, prioritise partners where adverse impacts are most likely to occur and most severe. Data still flows down the chain, but smaller suppliers should not receive open-ended ESG questionnaires by default — and that is now a statutory limit, not a courtesy. The practical takeaway for SMEs is to keep a clean, reusable supplier-evidence record so they can respond quickly when a request is genuinely necessary.

What This Means for Data Strategy

Companies should stop treating CSDDD and DPP as completely isolated compliance projects.

Instead of building one tool for legal due diligence and another for product data, it is highly beneficial to build a unified layer of supplier evidence. The audit trails collected to prove safe working conditions or environmental compliance under CSDDD are many of the same supporting documents that can help substantiate green claims under the Empowering Consumers Directive and support future DPP acts.

What Has Not Changed

It is important to be clear about what CSDDD does not do:

It does not change the timeline for sector-specific DPP delegated acts (e.g., textiles, chemicals, metals)
It does not replace the immediate need for carbon reporting under CBAM
It does not remove the battery passport deadline under Regulation (EU) 2023/1542 for February 2027

Important: While ESPR delegated acts remain forthcoming for textiles, chemicals, and metals, some product categories already have confirmed DPP mandates through standalone regulations: batteries from 18 February 2027 under Regulation (EU) 2023/1542, detergents from 23 September 2029, and toys from 1 August 2030. The supply-chain data overlap described above applies equally to these confirmed mandates.

What to Watch Next

How EU Member States transpose CSDDD into national law
The publication of sector-specific ESPR delegated acts, and how closely their supply-chain data fields mirror CSDDD mapping requirements
How quickly large brands begin sending mandatory data requests to their tier 1 and tier 2 suppliers

Official Source

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