CSDDD · Corporate Sustainability Due Diligence
Document CSDDD due diligence for critical minerals — before 2029 application
Directive (EU) 2024/1760 (CSDDD), as amended by Omnibus I (Directive (EU) 2026/470), requires in-scope companies to conduct due diligence along the chain of activities — human rights and environment, including critical raw materials in procurement. After Omnibus I the scope is narrower (indicative: >5,000 employees and >€1.5bn net worldwide turnover; third-country equivalents under national law). ZRG is not legal advice and does not certify CSDDD compliance.
Application
26 Jul 2029
Member States must transpose by 26 Jul 2028. Single application date for in-scope companies: 26 Jul 2029. First annual website statement: financial years starting on or after 1 Jan 2030. Commission due-diligence guidelines due by 26 Jul 2027.
Penalty cap
max 3% turnover
After Omnibus I: pecuniary penalties are capped at 3% of net worldwide turnover (the previous “not less than 5%” floor is gone). Actual fines are set by the Member State; EU-wide civil liability was removed.
Supply chain
Evidence missing
Corporate procurement and supervisors expect documented diligence for cobalt, rare earths, graphite — no file, no new-contract approval.
Concrete procurement risk scenario
How it plays out in practice — operational damage, not theory:
Step 1
CSDDD file requested by corporate procurement
Your customer demands the CSDDD due-diligence file for cobalt and rare earths by quarter-end. You have incomplete CoAs, no chain-of-activities mapping, no complaints-mechanism evidence.
Step 2
Supervisor reviews diligence — 3% cap
The national supervisor assesses missing identified impacts in the minerals chain. Fines are national, but capped at 3% of net worldwide turnover. In parallel: contract freeze at group level.
Step 3
Emergency sourcing without documented diligence
Supplier blocked, tight spot market, price spike. Replacement source without origin and diligence evidence — next audit risk and line stop.
What to check now
- Due diligence policy integrated into governance and risk management?
- Actual/potential impacts identified for critical minerals (primarily direct partners)?
- Complaints / notification mechanism documented and accessible?
- Suppliers, origin and evidence held audit-ready in the chain of activities?
How ZRG Mineral supports your CSDDD due diligence
ZRG is not legal advice — but it delivers the documented data base that procurement, supervisors and group compliance expect:
- · Audit trail & PDF certificate per validation
- · Field-matrix completeness + risk terminal score
- · Coverage map: make missing suppliers visible
- · Early warnings for geopolitical risk 6–8 weeks ahead
Not legal advice. Figures follow Directive (EU) 2024/1760 as amended by Omnibus I (Directive (EU) 2026/470). Obligations depend on company size, seat and national transposition.