The EU Corporate Sustainability Due Diligence Directive (CSDDD, Directive 2024/1760) entered into force on 25 July 2024 and requires large EU companies and non-EU companies with significant EU turnover to conduct mandatory human rights and environmental due diligence across their value chains. Cobalt supply chains, particularly those involving DRC artisanal mining, are among the highest-risk value chains under the CSDDD framework.
Scope and Thresholds
The CSDDD applies in phases based on company size. From 2027, companies with more than 5,000 employees and €1.5 billion global turnover must comply. From 2028, companies with more than 3,000 employees and €900 million turnover. From 2029, companies with more than 1,000 employees and €450 million turnover. Non-EU companies with equivalent EU turnover thresholds are also covered.
Cobalt-Specific Obligations
For companies with cobalt in their value chains, CSDDD requires: identification of actual and potential adverse human rights impacts (child labour, forced labour, unsafe working conditions in DRC ASM); integration of due diligence into corporate policies and risk management systems; taking appropriate measures to prevent, mitigate, and remediate adverse impacts; establishing and maintaining a complaints procedure; monitoring the effectiveness of due diligence measures; and publicly communicating on due diligence.
Relationship to EU Battery Regulation
The CSDDD and EU Battery Regulation create overlapping but complementary obligations for battery manufacturers. The Battery Regulation's due diligence requirements (Articles 48–52) are sector-specific and apply from August 2025. The CSDDD creates broader value chain obligations that apply from 2027–2029 depending on company size. Companies should design integrated compliance programs that satisfy both frameworks simultaneously.