The EU Corporate Sustainability Due Diligence Directive (CSDDD) will harmonize human rights and environmental due diligence across the EU — Vietnamese companies are not directly in scope, but every supplier in an EU group’s value chain will be asked, and the bar sits higher than today’s German LkSG or French vigilance law.
What the CSDDD is and who it covers
Directive (EU) 2024/1760, published 5 July 2024 and in force 25 July 2024, obliges large EU companies (1,000+ employees and net turnover above EUR 450m/year) and non-EU companies with EU turnover above EUR 450m to conduct due diligence on adverse human rights and environmental impacts across their entire “chain of activities” — broader than the LkSG’s “supply chain,” including downstream distribution. Core duties: identify, prevent, mitigate and remediate impacts; grievance mechanisms; disclosure; and civil liability for due-diligence failures causing harm. Administrative fines initially up to 5% of global turnover.
The post-Omnibus timeline: delayed, not cancelled
In February 2025 the Commission tabled the simplification Omnibus package; the “Stop-the-Clock” Directive (in force 17 April 2025) pushed national transposition to 26 July 2027 and first-phase application to 26 July 2028. Omnibus I goes further: transposition by 26 July 2028, all companies compliant from 26 July 2029 (no phasing), no mandatory climate transition plans, fines capped at 3% of global turnover, the EU-wide civil liability mechanism deleted (left to national law), and no last-resort duty to terminate business relationships. The message: the EU is easing the compliance burden, but the core due-diligence framework survives — Vietnamese businesses should not read “delayed” as “cancelled.”
How Vietnamese suppliers should prepare
EU groups will cascade duties through contracts — like the LkSG/vigilance mechanism but with a wider “chain of activities” and heavier documentation. Vietnamese suppliers should: (1) build a CSDDD-compatible due-diligence system now (policy, risk assessment, remediation, grievance, records) — one investment serving LkSG, French vigilance and CSDDD alike; (2) extend self-assessment to distribution/logistics if a direct supplier; (3) normalize environmental data (emissions, waste, water) since the CSDDD weights environment equally with human rights; (4) track transposition laws in key EU import states (Germany, France, Netherlands), as duty details and penalties are set nationally. Companies already LkSG/vigilance-ready have a head start — the CSDDD is an “upgrade,” not a rebuild.
Checklist
- Check whether EU customers fall in CSDDD scope (1,000 employees + EUR 450m).
- Build one due-diligence system serving LkSG/vigilance/CSDDD.
- Extend self-assessment to environment and distribution.
- Track transposition in Germany, France, Netherlands (duties vary by state).
- Keep full records — compliance evidence for audits.
Frequently asked questions
When does the CSDDD apply?
Under Omnibus I: EU states transpose by 26 July 2028; all in-scope companies comply from 26 July 2029 (no phasing as originally planned).
Are Vietnamese companies directly covered by the CSDDD?
Only with EU turnover above EUR 450m/year. Otherwise the impact is indirect, via contract requirements from in-scope EU customers.
How does the CSDDD differ from the LkSG?
A wider “chain of activities” (including distribution) than the LkSG’s supply chain; EU-wide harmonization instead of national laws; originally EU-wide civil liability and mandatory climate plans — since softened by the Omnibus.
What are the CSDDD fines?
Initially up to 5% of global turnover; Omnibus I proposes a 3% cap — the final figure is set by each state’s transposition law.
Already LkSG-compliant — anything more for the CSDDD?
The foundation is solid; “upgrade” by extending to distribution, weighting environment more heavily, and updating for each EU state’s transposition law.
Vietnamese suppliers to the EU should build CSDDD-compatible due diligence now — contact FLAT Law Firm for assessment and an upgrade roadmap from LkSG/vigilance to CSDDD.
This content is general information only, not legal advice for any specific matter. The Omnibus package is still moving through EU legislation; consult the original texts before applying. This article is pending internal quality review.
This article has been quality-reviewed by the FLAW AI Legal Council