--- title: "Chain of activities" description: "Chain of activities (CSDDD): the upstream and downstream business partners whose activities fall inside a company's due diligence duty." canonical: "https://gencompl.ai/glossary/chain-of-activities" language: "en-US" type: "Glossary term" published: "2026-10-13T21:29:30.207Z" modified: "2026-10-13T21:37:06.316Z" --- # Chain of activities 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; and 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. **What does "Chain of activities" mean under the CSDDD?** Defined in: [CSDDD](https://gencompl.ai/regulations/csddd) (32024L1760) [Home](https://gencompl.ai/) › [Glossary](https://gencompl.ai/glossary) › Chain of activities - (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)](https://gencompl.ai/regulations/csddd), 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](https://gencompl.ai/regulations/csddd) sets out which companies are in scope at all. > **What we could not establish** > > The definition fixes which activities count. It does not say which of a company's suppliers, distributors or service providers fall inside it, because that turns on the facts of each relationship. Member States apply their national measures from 26 July 2029 (Article 37(1), as replaced by Directive (EU) 2026/470), and as at 13 October 2026 the Dutch implementing bill is still a draft. This entry fixes the term. It does not decide whether the term catches your institution; counsel decides that. ## 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 diligence](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202401760) (EUR-Lex · 13 June 2024) - [Directive (EU) 2026/470, amending Directive (EU) 2024/1760](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202600470) (EUR-Lex · 24 February 2026) ## Related content ### Glossary term - [Adverse human rights impact](https://gencompl.ai/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](https://gencompl.ai/glossary/business-partner-csddd): 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’). ### Regulation - [Corporate Sustainability Due Diligence Directive (CSDDD)](https://gencompl.ai/regulations/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.