regulations

CSDDD and DPP: Why Supply Chain Mapping Supports DPP Readiness

How risk-based CSDDD due diligence can improve supply-chain evidence and support Digital Product Passport readiness.

3/23/2026 · 6 min read · InfoDPP

Update, 6 September 2026: the Commission’s guidelines on the Forced Labour Regulation (Regulation (EU) 2024/3015, applicable from 14 December 2027) list the unique identifier of the digital product passport among the product-identification data an investigating authority may gather. Some supply-chain records prepared for CSDDD or a passport may also be relevant to an investigation. The information required depends on the legal purpose and the case. Analysis →

What Is the CSDDD?

The Corporate Sustainability Due Diligence Directive (CSDDD), Directive (EU) 2024/1760 as amended, requires companies in scope to apply risk-based due diligence to adverse human-rights and environmental impacts in their chains of activities. It does not impose a universal audit of every supplier or a complete raw-material map. Companies first use reasonably available information to identify the areas where impacts are most likely and most severe, then assess those priority areas in greater depth. Information may be requested from business partners only when necessary, with additional restrictions for partners with fewer than 5,000 employees.

Directive (EU) 2026/470 sets general application from 26 July 2029, following national transposition by 26 July 2028. Article 16 reporting applies to financial years starting on or after 1 January 2030. The main thresholds are below; qualifying ultimate parent companies are also covered on a consolidated group basis, subject to the conditions in Article 2.

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, some of their supporting data may overlap:

1. Supplier mapping can support both tasks

Risk-based supplier mapping for CSDDD can provide evidence relevant to a product’s history. However, the applicable product rules determine which facility, supplier or origin data a DPP requires; CSDDD mapping does not establish that dataset.

2. Environmental evidence may be reusable

CSDDD requires risk-based assessment of relevant environmental impacts. Supplier evidence gathered for that purpose may also support product-level sustainability reporting, but the relevant ESPR product rules determine what data are needed.

3. The amendment limits how data flows down the chain

For in-depth assessments, information requests to any business partner must be necessary. For partners with fewer than 5,000 employees, the information must also be unavailable by other reasonable means. These Article 8(2a) safeguards concern CSDDD assessments, not every product-data request for another legal purpose. They apply through the relevant national implementing measures.

What This Means for Data Strategy

Companies should consider where CSDDD and DPP preparation can share evidence while keeping their legal requirements separate.

A shared, well-organised collection of supplier evidence can support both due diligence and product-data systems. The audit trails collected to prove safe working conditions or environmental compliance under CSDDD may also 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 Sources

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