Dejan Jasnic · Co-founder & Compliance Lead, Trusty · 20+ years anti-fraud & compliance · ACFE Swiss Chapter Board
CSDDD, EUDR, and national laws like Germany’s LkSG are three separate legal regimes that can all apply to the same company at once. CSDDD (Corporate Sustainability Due Diligence Directive) covers human rights and environmental impacts across a company’s full value chain, applies only to companies with 5,000+ employees and €1.5 billion+ turnover, and now takes effect from 26 July 2029. EUDR covers deforestation, forest degradation and legality risks in seven named commodities, has no company-size threshold, and applies from 30 December 2026 to operators, and to downstream operators and traders of any size; micro and small operators established as such by 31 December 2024, and natural persons, have until 30 June 2027, except for timber products listed in the Annex to the EU Timber Regulation. National laws such as Germany’s LkSG have been in force since 2023 with their own, generally lower, thresholds, and continue to apply independently; Germany plans to replace the LkSG with the law transposing the CSDDD.
Why this comparison matters
It’s a common – and costly – assumption that one due diligence programme can satisfy every EU supply chain law at once. It can’t. Each regime was built with a different target, a different company threshold, and its own enforcement timeline. A company can be in scope of all three simultaneously and owe different documentation to different authorities.
CSDDD, EUDR, and national laws side by side
CSDDD | EUDR | National laws (e.g. LkSG) | |
|---|---|---|---|
What it covers | Human rights and environmental impacts, full value chain | Deforestation, forest degradation and legality risks in 7 named commodities (cattle, cocoa, coffee, palm oil, rubber, soy, wood) | Human rights and environment, scope set by each country |
Who's in scope | EU companies with 5,000+ employees and €1.5B+ turnover (plus equivalent non-EU companies) | Any operator, downstream operator or trader placing, making available or exporting covered commodities and products - no size threshold | Germany's LkSG: at least 1,000 employees in Germany (3,000 until 2023); still in force in 2026 but enforced more lightly, and to be replaced by the law transposing the CSDDD; other states vary |
Current timeline | Transposition by 26 July 2028; applies from 26 July 2029 (reporting from FY2030) | Operators, downstream operators and traders: 30 Dec 2026; micro/small operators established by 31 Dec 2024 and natural persons: 30 June 2027 (not EUTR timber) | Already in force (Germany's LkSG since 2023) |
Core obligation | Ongoing due diligence across the value chain, with civil liability for breaches | Due diligence system reviewed yearly (Article 12); due diligence statement (DDS) before placing on the market or export, geolocation traceability | Varies by country; LkSG requires risk analysis and grievance mechanisms |
CSDDD's timeline has already moved twice
The CSDDD (Directive 2024/1760) was adopted in May 2024 with a staggered rollout originally starting in 2027 for the largest companies. Two rounds of simplification changed that:
- Omnibus I (December 2025) narrowed the scope to companies with 5,000+ employees and €1.5 billion+ turnover – up from the original, broader thresholds.
- A further amendment (Directive (EU) 2026/470) removed the staggered rollout entirely and set a single application date of 26 July 2029 for all in-scope companies, with Article 16 reporting obligations pushed to financial years starting on or after 1 January 2030.
Member states now have until 26 July 2028 to transpose the directive into national law – two years later than the original transposition deadline.
EUDR doesn't care how big you are
Unlike CSDDD, the EUDR has no employee or turnover threshold. Any operator, downstream operator or trader placing on the EU market, making available on it or exporting cattle, cocoa, coffee, palm oil, rubber, soy, wood, or derived products listed in Annex I is in scope, regardless of company size – though micro and small operators established as such by 31 December 2024, and natural persons, get an extra six months (until 30 June 2027) to comply, except for timber products listed in the Annex to the EU Timber Regulation. The obligation is also structured differently: EUDR requires operators to maintain a due diligence system reviewed at least once a year (Article 12) and to submit a due diligence statement before the products are placed on the market or exported (one statement can cover several shipments within one year of submission), backed by plot-level geolocation data.
National laws didn't wait for Brussels
Some member states already had their own due diligence laws before CSDDD existed. Germany’s Supply Chain Due Diligence Act (Lieferkettensorgfaltspflichtengesetz, or LkSG) has applied since 2023 to companies with at least 1,000 employees in Germany (3,000 until 2023), a lower threshold than CSDDD ultimately adopted. It is still in force in 2026 but enforced more lightly, and Germany plans to replace it with the law transposing the CSDDD (see where the LkSG stands in 2026). This means a German company may need to track two overlapping but not identical rulebooks during the transition, and national laws remain independently enforceable regardless of when CSDDD applies.
Can one company be subject to all three?
Yes. Consider a large company sourcing cocoa into Germany:
- EUDR requires a due diligence statement and geolocation traceability for the cocoa shipment itself, starting December 2026.
- Germany’s LkSG already requires supply chain risk analysis and grievance mechanisms today.
- CSDDD will require broader human rights and environmental due diligence across the company’s full value chain from 2029, if the company meets the 5,000-employee/€1.5B threshold.
These aren’t substitutes for one another – satisfying one doesn’t automatically satisfy the others.
Frequently asked questions
No. EUDR's due diligence statement is commodity- and product-specific; CSDDD requires a broader, ongoing due diligence programme across human rights and environmental impacts. They can overlap in scope but don't substitute for each other.
26 July 2029 for in-scope companies, following amendments that removed the original staggered 2027-2028 rollout. Member states must transpose the directive into national law by 26 July 2028.
No. EUDR applies to any operator, downstream operator or trader placing, making available or exporting covered commodities and products, regardless of employee count or turnover, though micro and small operators established as such by 31 December 2024, and natural persons, get a later compliance date (30 June 2027), except for timber covered by the EU Timber Regulation.
Not automatically. National laws continue to apply independently until they are changed. Germany's LkSG is still in force in 2026, though enforced more lightly, and Germany plans to replace it with the law transposing the CSDDD.
Sources: Directive (EU) 2024/1760 (CSDDD) as amended by Directive (EU) 2025/794 and Directive (EU) 2026/470; European Commission corporate sustainability due diligence guidance; Regulation (EU) 2023/1115 (EUDR); German Lieferkettensorgfaltspflichtengesetz (LkSG).
Tracking obligations across multiple overlapping due diligence regimes gets complicated fast. Trusty’s compliance platform helps map EUDR, CSDDD, and national due diligence requirements in one place instead of three spreadsheets.
Related reading: whether you are an EUDR operator or a trader, how SMEs can screen suppliers without a compliance team, and EUDR Passport for the deforestation side of the obligations.
Need software for EUDR due diligence? EUDR Passport is free to set up, free for your suppliers, and costs €90 per product profile per year with unlimited DDS.
30 DECEMBER 2026
FREE EUDR Obligations Checker: Answer a few simple questions and get an instant assessment of your EUDR obligations.