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We provide comprehensive advice on sustainability in the supply chain. The German legislator and the European Union have issued numerous regulations on human rights, CO2 emissions, biodiversity and resource conservation, which impose extensive obligations on companies. We support our clients in analyzing how their supply chains are affected and developing strategies to efficiently comply with such obligations or mitigate their impact. For this we draw on our many years of experience and expertise in the field of customs and foreign trade.
The German Supply Chain Due Diligence Act (LkSG) has been in force since 2023 and has been applicable to companies with at least 1,000 employees in Germany since 2024. With the EU Directive on Corporate Sustainability Due Diligence (CSDDD), strict human rights and environmental protection standards in supply chains will apply to companies throughout Europe and, in some cases, worldwide. Companies must identify and assess the risks of human rights violations in their supply chains and take appropriate measures. Non-compliance may result in fines, exclusion from public contracts and claims for damages.
The EU has introduced the Carbon Border Adjustment Mechanism (CBAM), which provides for the pricing of certain CO2-intensive imported goods such as iron, steel, and aluminium. Since 1 October 2023, importers have been subject to reporting obligations. Starting in 2026, importers must obtain the status of authorised CBAM declarants and purchase CBAM certificates corresponding to the embedded emissions of imported goods. The Regulation applies to all importers, regardless of their size, and is also highly important for logistics service providers. Companies urgently need to prepare for its implementation. Otherwise, they face the risk of disrupted supply chains and substantial fines.
The Regulation on Deforestation-Free Supply Chains (EUDR) provides for comprehensive due diligence obligations for the placing on the market, making available and exporting of relevant commodities, namely cattle, coffee, cocoa, palm oil, soya, rubber and wood as well as products thereof. Amongothers, the regulation only permits the import and export of relevant products if they are deforestation-free, have been produced in accordance with the legislation of the producing country and a due diligence declaration has been submitted to an information system. The EUDR requires comprehensive supply chain transparency right back to the commodity's place of origin. Shortly before the regulation was due to come into force, the date of application for medium-sized and large companies was postponed to 30 December 2025. The companies affected have thus gained time, which they should use for implementation.
In December 2024, the EU issued a regulation banning products made with forced labour on the EU market. This measure is intended to strengthen the protection of human rights in supply chains and complements the EU Directive on Corporate Sustainability Due Diligence (CSDDD). Companies need to make their supply chains more transparent, conduct detailed risk analysis, and regularly review their suppliers to ensure that there is no forced labor in the supply chain. Otherwise, there is a risk of an import ban, among other things. This requires an active approach and training for staff to increase awareness of the risks of forced labour.
The EU Ecodesign for Sustainable Products Regulation (ESPR) is a key regulation of the European Green Deal (Circular Economy) that sets out sustainable ecodesign requirements for products and replaces Directive 2009/125/EC. It applies to almost all products, with exceptions such as food and pharmaceuticals, and requires documentation in the form of digital product passports. The first requirements for textiles, steel and furniture will be published in 2026 and will apply from 2027. If the products do not comply with ecodesign, they may not be imported, among other consequences.
The ESPR also contains bans on destruction of consumer products, which are to entered into force from mid-2025.
With the new Waste Shipment Regulation, which entered into force on 20 May 2024, the EU has introduced a new and more extensive system for monitoring and controlling waste shipments within and outside its borders in order to protect the environment and public health. The new Waste Shipment Regulation therefore reflects a cross-border circular economy. The regulation provides for export restrictions as of May 2027. As of November 2026, no plastic waste may be exported to non-OECD countries. The regulation aims to prevent illegal waste shipments and improve the traceability of waste shipments. Companies that export waste must prove that the waste is treated in an environmentally sound manner at the recipient facility. An EU-wide enforcement network will be set up to strengthen cooperation and coordination against illegal waste shipments.
The EU Packaging and Packaging Waste Regulation (PPWR) is part of the Circular Economy Action Plan and aims to reduce the environmental impact of packaging. The PPWR provides for various design specifications for packaging that aim to reduce packaging weight, promote the circular economy and implement extended producer responsibility. A large number of specific requirements will be laid down by the European Commission in delegated acts once the PPWR comes into force. The objective is for all packaging in the EU to be recyclable by 2030. The PPWR requires significant changes for packaging supply chains and cycles.
The EU Battery Regulation entered into force on 17 August 2023. The Battery Regulation establishes sustainable design requirements for batteries to reflect the concept of circular economy. In particular, CE marking and the registration of a digital product passport are required. On the one hand, the Battery Regulation therefore provides for ecodesign requirements as they will be determined for other products in the Ecodesign Regulation. On the other hand, Chapter VII provides for due diligence obligations along the supply chain, which in turn allow synergies with the requirements of the German LkSG.
The EU Conflict Minerals Regulation, in force since 1 January 2021, aims to ensure responsible trade in tin, tantalum, tungsten and gold from conflict-affected areas. Companies must fulfil due diligence obligations in their supply chain to ensure that their purchases do not contribute to the financing of armed conflicts. The regulation applies to all companies, regardless of their size, and affects all conflict regions worldwide. Companies are required to implement a management system, assess risks, organise independent audits and report transparently on their practices.
