The problem: the rule you read about last year no longer exists
Many Vietnamese suppliers were told in 2024-2025 that the EU’s Corporate Sustainability Due Diligence Directive (CSDDD) would force their European customers to adopt climate transition plans aligned with 1.5 degrees Celsius — and to demand emissions data down the chain. That was true under the original directive. It is no longer true: the Omnibus I Directive rewrote the CSDDD before a single company had to comply with it. Acting on the old version wastes money; ignoring the new version misses the duties that survived.
The legal basis — read the current text, not the 2024 summaries
- Directive (EU) 2024/1760 (CSDDD), entered into force 25 July 2024. Its original Article 22 required in-scope companies to adopt a climate transition plan.
- Directive (EU) 2026/470 (Omnibus I), published in the Official Journal on 26 February 2026 and in force since 18 March 2026: removed the mandatory climate transition plan obligation; raised the scope to EU companies with more than 5,000 employees and net worldwide turnover above EUR 1.5 billion (non-EU companies: EUR 1.5 billion EU turnover); set a single transposition deadline of 26 July 2028 and a single application date of 26 July 2029; capped fines at 3% of net worldwide turnover; and left civil liability to national law. In force as of 19 October 2026.
- What survived: the core duty to identify and address adverse human-rights and environmental impacts — climate included — on a risk basis, prioritising direct business partners; and the value-chain information duties that let customers ask suppliers for data.
What this means for a Vietnamese supplier
The legal duty is gone; the commercial demand is not. European customers still ask for greenhouse-gas data and transition plans — now as contract terms, tender conditions and bank requirements rather than as CSDDD compliance. A supplier that answers “the law no longer requires it” will simply lose the order to one that provides the data. Scope shrank, but the trickle-down did not. Far fewer companies are directly regulated, yet those that remain still cascade questionnaires down their chains — and the Omnibus expressly limited what they may demand from smaller partners, so oversized questionnaires can now be pushed back against with a legal argument. Dates moved, not cancelled. With application from 26 July 2029, there is time to build proper emissions measurement — time that should be used, because customers’ contractual deadlines have not moved with the statute.
A proportionate action plan
Do not build a full 1.5 degrees Celsius transition plan because a 2024 article told you to. Do this instead: (1) start measuring Scope 1 and 2 emissions now — every serious customer questionnaire begins there; (2) map where Scope 3 data would come from, without promising what you cannot measure; (3) adopt a short, honest climate statement (what you measure, what you are reducing, by when) rather than a glossy plan nobody will audit; (4) when a customer demands data beyond your capacity, answer with what you have plus a timeline — and know that the Omnibus value-chain cap gives smaller partners a legal basis to refuse disproportionate requests. Keep all of it documented: under the surviving due-diligence duty, the paper trail is the compliance.
Frequently asked questions
Does our German customer still need a climate transition plan?
Not as a CSDDD legal duty — Omnibus I removed it. It may still need one for its CSRD/ESRS reporting (if in scope there), for investors, or voluntarily. Ask which driver sits behind the request; the answer changes what you must deliver.
Can we refuse a 200-question climate questionnaire?
You can negotiate it down. The Omnibus limits what in-scope companies may request from smaller value-chain partners to proportionate information. A polite, reasoned pushback citing disproportionate burden is now legally grounded — but refusing all cooperation is still a commercial dead end.
Will the rules change back?
The Commission has signalled the simplification agenda continues into 2026, and the political direction is stable for now. Track the transposition in the member states where your customers sit — national law is where the final duties will land by July 2028.
This article has been quality-reviewed by the FLAW AI Legal Council
