The planned EU supply chain law has overcome a decisive hurdle: Despite resistance from the German government, a majority of EU countries support the law to protect human rights. It is intended to ensure that European companies guarantee compliance with human rights and environmental standards in their supply chains – including with their suppliers. In future, companies will have to prove that their imported products from third countries have been manufactured without child labour or environmental damage. The adopted draft is less strict than originally envisaged: The law now applies to companies with 1,000 or more employees and an annual turnover of at least 450 million euros, instead of 500 or more employees and 150 million euros turnover as initially planned. The possibility of civil liability has also been weakened. The EU member states, the EU Parliament and the Commission had already agreed on the law in December.
What companies now need to consider:
- Due diligence obligations: Carrying out risk analyses and taking preventative measures.
- Documentation: Regular reports on compliance with standards must be prepared and made publicly available.
- Complaints mechanisms: Establishment of systems for anonymous reporting of violations.
- Contract adjustments: Ensuring that suppliers comply with standards.
- Data protection: Compliance with the GDPR in data processing.
Due to our duty to provide information as your external data protection officer, we would like to sensitise you to these issues and will be happy to answer any questions you may have at any time.