Chain of activities
What does "Chain of activities" mean under the CSDDD?
- (i) activities of a company’s upstream business partners related to the production of goods or the provision of services by that company, including the design, extraction, sourcing, manufacture, transport, storage and supply of raw materials, products or parts of products and the development of the product or the service
- (ii) activities of a company’s downstream business partners related to the distribution, transport and storage of a product of that company, where the business partners carry out those activities for the company or on behalf of the company, and excluding the distribution, transport and storage of a product that is subject to export controls under Regulation (EU) 2021/821 or to the export controls relating to weapons, munitions or war materials, once the export of the product is authorised
Defined in / by
- CSDDD (32024L1760), Article 3(1), point (g)
Last updated: 13 October 2026.
What the definition covers
The Directive builds its due diligence duties around the chain of activities, not around the company alone. The term appears, among others, in Articles 8, 10, 11, 15 and 29, so a reader who misjudges its edges misjudges the reach of the whole regime.
Point (i) looks upstream and is broad. It names design, extraction, sourcing, manufacture, transport, storage and supply of raw materials, products or parts of products, and the development of the product or the service. Point (ii) looks downstream and is narrower. It names only distribution, transport and storage of the company's product, and only where the business partner does that for the company or on its behalf. Use of the product by customers is not named, and neither are disposal or recycling. A carve-out removes distribution, transport and storage of a product subject to export controls under Regulation (EU) 2021/821, or to export controls on weapons, munitions or war materials, once the export is authorised.
For regulated financial undertakings the reach is smaller still. Recital 26 of the Directive states that only the upstream part of the chain of activities is covered for them. The CSDDD page sets out which companies are in scope at all.
Questions and answers
Does the chain of activities include a company's customers?
Only in part. Point (ii) reaches downstream business partners that distribute, transport or store the company's product for it or on its behalf. The text does not name use of the product by customers or its disposal.
Is the chain of activities the same for banks and insurers?
No. Recital 26 of the Directive states that for regulated financial undertakings only the upstream part of the chain of activities is covered.
Sources
- Directive (EU) 2024/1760 on corporate sustainability due diligenceEUR-Lex · 13 June 2024
- Directive (EU) 2026/470, amending Directive (EU) 2024/1760EUR-Lex · 24 February 2026
Glossary
Adverse human rights impact
An impact on persons resulting from an abuse of one of the human rights listed in Part I, Section 1, of the Annex to this Directive, as those human rights are enshrined in the international instruments listed in Part I, Section 2, of the Annex to this Directive; or an abuse of a human right not listed in Part I, Section 1, of the Annex, but enshrined in the human rights instruments listed in Part I, Section 2, of the Annex, provided that the three conditions of point (c)(ii) are met.
Business partner
An entity (i) with which the company has a commercial agreement related to the operations, products or services of the company or to which the company provides services pursuant to point (g) (‘direct business partner’); or (ii) which is not a direct business partner but which performs business operations related to the operations, products or services of the company (‘indirect business partner’).
Regulations
Corporate Sustainability Due Diligence Directive (CSDDD)
The Corporate Sustainability Due Diligence Directive is Directive (EU) 2024/1760. After Omnibus I, Member States must transpose it by 26 July 2028 and apply it from 26 July 2029, to companies with more than 5,000 employees and EUR 1.5 billion in net worldwide turnover. The Netherlands has a draft bill, the Wivo, which names the ACM as supervisor.
NextCommission adopts guidelines under Article 19(2), points (a), (d) and (e), and guidance on model contractual clauses (Article 18)