Read this article in:
English
20 August, 2026IndustriAll Europe and IndustriALL Global Union call on the European Commission to put workers, trade unions and social dialogue at the heart of the future guidelines on the implementation ofthe new Corporate Sustainability Due Diligence Directive (CSDDD).
The aim of the guidelines is to provide companies with practical, step-by-step instructions and clear criteria on how to fulfill their due diligence obligations in daily operations, ensuring the rules remain realistic, unified, and legally predictable. However, trade unions warn that this focus on practicality should not compromise impact. In a joint submission to the Commission’s consultation on these guidelines, industriAll Europe and IndustriALL Global Union have stressed that effective human rights due diligence cannot be reduced to a corporate compliance exercise. It must deliver tangible improvements for workers along global supply chains.
The submission draws on lessons from the joint “ABC of RBC” project, which has equipped trade union networks with practical tools to navigate responsible business conduct and due diligence. Through exchanges covering the garment, steel, mining and automotive sectors, the project has gathered first-hand evidence of what works – and where current approaches fall short.
Sectoral realities demand different approaches
One clear lesson is that one size does not fit all. Garment supply chains are characterised by fragmented subcontracting and purchasing practices that make risks difficult to trace. Extractive industries face severe human rights and environmental risks, while automotive and metals are confronting new challenges linked to critical raw materials, batteries and the green transition. The Commission’s guidelines must recognise these sectoral realities and address the structural causes of labour and human rights abuses, according to the union federations.
Crucially, workers and their representatives must be directly involved. Audits, questionnaires and multi-stakeholder initiatives cannot substitute genuine worker participation and independent trade union oversight. Workers are often the first to identify problems, making trade unions an essential early-warning system for risks in supply chains.
Companies should therefore provide worker representatives with the information, training and dedicated time needed to participate effectively in due diligence. Existing cross-border instruments, including Global Framework Agreements, should also be promoted as key tools for putting due diligence into practice globally.
At the heart of the submission is a clear demand: freedom of association and collective bargaining must be recognised as enabling rights.
Where workers cannot organise freely or report problems without fear of retaliation, serious risks remain hidden. This can mean unsafe conditions and toxic exposure in sectors like mining, metals and automotive, or wage theft, gender-based violence and precarious work in fragmented garment supply chains.
The Commission must ensure that freedom of association is central to assessing risks throughout supply chains.
“Due diligence cannot be something that companies do about workers without workers. Trade unions are on the ground every day and know where the risks lie. If workers cannot organise, bargain collectively and raise concerns without fear, abuses will remain hidden. The Commission’s guidelines must therefore put trade unions and social dialogue at the heart of implementation – not as a box to tick, but as the foundation for making due diligence deliver real change,”
said Judith Kirton-Darling IndustriAll Europe’s general secretary
The message is clear: if the CSDDD is to deliver real change rather than another layer of corporate compliance reporting, its implementation must be built around workers, trade unions and strong social dialogue.
Says IndustriALL Global Union general secretary Atle Høie:
“From the garment factories of Bangladesh to the mines and steel plants we’ve covered through the ABC of RBC project, the evidence is the same: workers know where the risks are, and trade unions can act on that knowledge. Guidelines that sideline collective bargaining and freedom of association will fail the workers this directive is meant to protect. The Commission has a chance to make due diligence mean something real, and that starts with putting unions at the table, not on the sidelines.”