CSDDD supply chain & human rights risk assessment
CSDDD due diligence is risk-based. You are not asked to audit everything equally - you scope where adverse human-rights and environmental impacts are most likely and most severe, then go deeper there first. The practical way to do that is to score risk across three dimensions: country, sector and product or commodity. The reference below is a starting heuristic for the country dimension.
The short version
- The CSDDD has no official country list and no legal risk tiers - unlike the EUDR. Risk-based scoping is your own assessment of severity and likelihood.
- Score risk as country × sector × product/commodity, identify the salient issues (the most severe potential impacts), then prioritise.
- The tiers here are an indicative heuristic drawn from recognised public indices - a place to start, not a legal determination. A lower-risk country can still host severe impacts in a specific sector or site.
How risk-based scoping works
From the whole chain to the priorities that matter
Step 2 of the CSDDD six-step cycle is to identify and assess actual and potential adverse impacts. Under Omnibus I this became a risk-based scoping exercise rather than full mapping of every tier: map your chain of activities at a high level, then focus assessment where risk is highest. This mirrors the OECD Due Diligence Guidance.
- 1
Map at a high level
Sketch your own operations and chain of activities - countries, sectors, key commodities and direct (tier-1) business partners.
- 2
Score the risk
Combine country, sector and product signals to flag where adverse impacts are most likely and most severe.
- 3
Find salient issues
Name the most severe potential impacts (e.g. forced labour, freedom of association, water) for each priority area.
- 4
Prioritise by severity
Rank by severity first (scale, scope, irremediability), then likelihood. Go deepest where harm could be worst.
Severity comes before likelihood: a less-likely but catastrophic impact can outrank a frequent but minor one. See the full supply chain risk assessment guide for how to weight the two.
What the tiers mean
An indicative country heuristic - three tiers
Lighter scoping, still required
Consistently strong governance, labour-rights and environmental signals across the indices. You still scope sector and product risk - a strong country can host a weak sector - but it is rarely where you start.
The default - scope on sector & product
Mixed signals: material salient risks in some sectors, decent in others. This is the sensible default for most sourcing geographies. The sector and commodity decide how much attention each one needs.
Prioritise - assess deeper, sooner
Weak signals across several indices - systemic forced or child labour, suppressed freedom of association, very weak rule of law, or conflict-affected areas (CAHRA). Strong candidates for early, deeper assessment and engagement.
Tiers are a qualitative reading of recognised public indices: the ITUC Global Rights Index (labour rights and freedom of association), the US State Department Trafficking in Persons tiers, the Transparency International Corruption Perceptions Index, the World Bank Worldwide Governance Indicators and the Environmental Performance Index. We deliberately do not reproduce precise scores - use those sources for current figures.
A starting heuristic, not a legal determination
36 countries shown
| Country | Region | Indicative tier | Salient issues to scope |
|---|---|---|---|
| AustraliaAU | Oceania | Lower | Strong governance and Modern Slavery Act reporting; horticulture migrant-labour risk persists.
|
| BangladeshBD | Asia | Higher | Apparel/textile sector with documented child labour, building & fire safety, and freedom-of-association risks.
|
| BrazilBR | Americas | Standard | Modern-slavery "dirty list" in cattle, charcoal and agriculture; Amazon deforestation exposure.
|
| CambodiaKH | Asia | Higher | Garment, brick and fishing sectors with debt bondage, child labour and weak freedom of association.
|
| CanadaCA | Americas | Lower | Strong governance and labour rights; a supply-chain forced-labour reporting law in force.
|
| ChinaCN | Asia | Higher | State-imposed forced labour concerns (notably Xinjiang); no independent trade unions; restricted freedom of association.
|
| ColombiaCO | Americas | Standard | Elevated risk to trade unionists; coffee and agriculture informal labour; post-conflict areas.
|
| Côte d'IvoireCI | Africa | Standard | World-leading cocoa producer with persistent child-labour risk on smallholder farms.
|
| Democratic Republic of the CongoCD | Africa | Higher | Cobalt and 3TG mining linked to child labour, conflict financing and hazardous artisanal conditions (CAHRA).
|
| DenmarkDK | Europe | Lower | Top-ranked on corruption perceptions and labour rights; strong environmental performance.
|
| EthiopiaET | Africa | Standard | Emerging apparel sourcing with very low wages, a weak union framework and conflict-affected regions.
|
| FranceFR | Europe | Lower | Strong governance and the original "duty of vigilance" law; residual sub-sector and migrant-labour risks.
|
| GermanyDE | Europe | Lower | Strong rule of law and labour rights; already has its own supply-chain due-diligence law (LkSG).
|
| GhanaGH | Africa | Standard | Cocoa child-labour risk and hazardous artisanal gold mining; relatively stronger governance regionally.
|
| IndiaIN | Asia | Higher | Large informal economy with documented bonded/child labour in textiles, stone, brick kilns and agriculture.
|
| IndonesiaID | Asia | Standard | Palm oil, fishing and mining with forced/child labour and deforestation risks in specific supply chains.
|
| JapanJP | Asia | Lower | Strong governance; watch the "technical intern" migrant-trainee programme for forced-labour indicators.
|
| MalaysiaMY | Asia | Standard | Migrant-labour forced-labour indicators (recruitment fees, passport retention) in electronics, gloves and palm oil.
|
| MexicoMX | Americas | Standard | Agricultural day-labour and child-labour risks; corruption and rule-of-law weaknesses in some regions.
|
| MoroccoMA | Africa | Standard | Textiles and agriculture (berries, tomatoes); child-labour and seasonal-worker risks.
|
| MyanmarMM | Asia | Higher | Conflict-affected (CAHRA) since the 2021 coup; forced labour, severe civil-rights restrictions, military-linked supply chains.
|
| NetherlandsNL | Europe | Lower | Strong institutions and labour rights; watch agricultural and warehouse migrant-labour conditions.
|
| New ZealandNZ | Oceania | Lower | Consistently strong governance and labour-rights signals.
|
| NigeriaNG | Africa | Higher | High corruption and weak rule of law; trafficking, child labour in mining/agriculture, and oil-sector environmental harm.
|
| PakistanPK | Asia | Higher | Bonded and child labour in agriculture, brick kilns and surgical/textile manufacturing; weak labour enforcement.
|
| PeruPE | Americas | Standard | Mining and agriculture (coffee, agro-export) with informal labour and environmental conflicts.
|
| PhilippinesPH | Asia | Standard | Electronics and agriculture; serious risks to labour-union organisers and child labour in some sectors.
|
| RussiaRU | Europe | Higher | Conflict-affected and heavily sanctioned; suppressed civil society and independent unions; sanctions/integrity exposure.
|
| South AfricaZA | Africa | Standard | Strong labour law but mining and farm-worker risks, high inequality and corruption pressures.
|
| SwedenSE | Europe | Lower | Consistently strong governance, labour-rights and environmental-performance signals.
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| ThailandTH | Asia | Standard | Documented forced labour and trafficking of migrant workers in fishing and seafood processing.
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| TürkiyeTR | Europe | Standard | Textile hub with Syrian-refugee and child-labour risks; pressured civil society and union rights.
|
| United KingdomGB | Europe | Lower | Strong rule of law and Modern Slavery Act reporting; residual risks in agriculture and care/cleaning labour.
|
| United StatesUS | Americas | Lower | Strong rule of law overall; pockets of agricultural and prison-labour risk warrant sector-level scoping.
|
| UzbekistanUZ | Asia | Higher | Historically state-organised forced labour in the cotton harvest; reforms ongoing but legacy risk remains.
|
| VietnamVN | Asia | Standard | Major electronics, footwear and seafood exporter; restricted independent unions, but an improving labour framework.
|
Showing 10 higher-risk, 15 standard-risk and 11 lower-risk countries from a representative set of 36. This is a curated selection, not an exhaustive list. Any country not shown should be scoped on its own indices alongside your sector and product context.
This is information, not legal advice, and not an official EU classification. Confirm against the primary indices and your own assessment. Not sure whether the CSDDD even applies to you? Try the scope checker.
The second dimension
High-risk sectors to weigh against the country
Country risk is only half the picture. These sectors recur across human rights and environmental sources as carrying salient risks almost wherever they operate. A standard-risk country sourcing in a high-risk sector can easily outrank a higher-risk country in a benign one.
Agriculture & food
Smallholder cocoa, coffee, cotton, palm oil, fishing & seafood - recurring child labour, forced labour, low wages and deforestation.
- Child labour
- Forced labour
- Environmental
Apparel, textiles & footwear
Long, fragmented chains with excessive hours, suppressed unions, building/fire safety and home-working child labour.
- Health & safety
- Freedom of association
- Child labour
Electronics & minerals
3TG and cobalt sourcing tied to conflict financing and artisanal/child mining; long sub-tier visibility gaps.
- Conflict minerals
- Child labour
Mining & extractives
Hazardous conditions, community displacement, water and land impacts, and corruption around concessions.
- Health & safety
- Environmental
- Corruption
Construction
Heavy reliance on migrant labour with recruitment-fee debt bondage, passport retention and unsafe sites.
- Forced labour
- Migrant labour
- Health & safety
Fishing & aquaculture
Distant-water and processing work with trafficking, forced labour at sea and IUU/environmental harm.
- Forced labour
- Trafficking
- Environmental
For goods with documented forced- or child-labour links by country and sector, the US Department of Labor List of Goods is a useful cross-check.
Sources
- [1]European Commission - Corporate Sustainability Due Diligence (CSDDD)retrieved 8 Jun 2026
- [2]OECD Due Diligence Guidance for Responsible Business Conduct (risk-based due diligence)retrieved 8 Jun 2026
- [3]ITUC Global Rights Index (labour rights & freedom of association)retrieved 8 Jun 2026
- [4]US State Department - Trafficking in Persons Report (country tiers)retrieved 8 Jun 2026
- [5]Transparency International - Corruption Perceptions Indexretrieved 8 Jun 2026
- [6]World Bank - Worldwide Governance Indicatorsretrieved 8 Jun 2026
- [7]Yale - Environmental Performance Indexretrieved 8 Jun 2026
- [8]US Department of Labor - List of Goods Produced by Child or Forced Laborretrieved 8 Jun 2026
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