overview
National Supply
Chain Laws
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Country Name & Status
DE LkSG (effective Jan 2022)
Loi de vigilance
FR
(effective 2017)
AGEC - Loi anti-gaspillage
pour une économie circulaire
(effective 2020; applicable for
fashion in 2023)
Uyghur Forced Labor
USA Protection Act (effective
June 2021)
New York Fashion
Sustainability Act (first draft
Oct 2021)
Dodd-Frank Act (effective
July 2010)
California
Transparency
in Supply chains Act
CTSCA (effective 2010)
Trafficking Victims
Protection Act -TVPA
(effective 2000)
Corporate Sustainability
EU Reporting Directive
(confirmed Nov 2022;
effective Jan 2024)
Transparency Act (effective
NO
July 2022)
UK Modern Slavery Act
(effective 2015)
Child Labor Due Diligence
NE
Act (effective 2019)
Supply Chain Act for a social,
human-rights-compliant
AT
and sustainable production
method (draft date 2021)
Environmental protection
law focused on preventing
CH
environmentally harmful
activities (draft 2022)
Due diligence bill proposal
BE for companies throughout
their supply chains (draft
date April 2021)
MSA NSW Modern Slavery
AUS
Acts of Australia (2018) and
of New South Wales (2018)
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ESG Factors Risks
Environmental Human trafficking,
Social & Governance slavery, forced labour
Human rights,
employee rights
Environmental
(healthy & safety)
Social & Governance
and environmental
protection)
Environmental
Environmental protection, waste reduction,
information transparency
Social & Governance Forced labor and slavery
Environmental Environmental and
Social & Governance social risks
Environmental Conflict minerals
Slavery and human
Social & Governance trafficking in entire
supply chain
Social & Governance Human trafficking
Whole supply chain, human
Environmental
rights, employee rights and
Social & Governance
environmental protection
Human rights and working
Social & Governance
conditions (all tiers)
Human trafficking,
Social & Governance
slavery, forced labour
Child labor, human rights,
Social & Governance employee rights and
environmental protection
Environmental Human rights, employee rights
Social & Governance and environmental protection
Environmental Human rights, employee rights
Social & Governance and environmental protection
Environmental Human rights, employee rights
Social & Governance and environmental protection
Modern slavery, dangerous
Environmental
or substandard working
Social & Governance
conditions
Scopes
From 2023 companies
with >3K employees
From 2024 companies
with >1,000 employees
Companies with >5.000
french empl. or > 10.000
international empl.
Companies with >50M€ or
25K units (Jan 2023); >20M€
or 10K units (Jan 2024) >10M€
or 10K units (Jan 2025)
All US importers with possible
ties to supply chains in
Western China
Fashion firms with US
business and >$100M
revenue
All stock listed companies
California – companies gross
receipts of $100 million or
more
USA
EU companies with > 250
employees and/or €40M
turnover and/or €20 M Total
assets
>50 empl. or 70 m revenue
or 35 m assets (2 out of 3)
Global revenue > £36M or
part of a business in UK
>250 empl. or 40 m
revenue or 20 m assets
(2 out of 3)
Tbd.
>250 empl. & 40 m revenue
SME if operate in high risk
area
>250 empl. & 50 m revenue
SME if operate in high-risk
area
>$100M revenue
Obligations
Risk management
annual report / plan
grievance mechanism
Risk management
annual report / plan
grievance mechanism
Supply chain traceability,
data analysis, product
environmental footprinting,
consumer communication
Import documentation
incl. practices to
prevent risks
OECD guidelines, risk
management, anual report
/ plan, map (over 50%) supply
chain, product base reporting
Reporting
Reporting, auditing /
certification, training
OECD guidelines, risk
management, annual report
/ plan, map (over 50%) supply
chain, product base reporting
Environmental protection,
risk management, annual
report / plan, grievance
mechanism
OECD guidelines, risk
management, annual
report / plan
Code of conduct, risk
management, annual
report / plan, training
Risk management,
annual report / plan,
grievance mechanism
Risk management,
annual report / plan,
grievance mechanism
Risk management,
annual report / plan,
grievance mechanism
Risk management,
annual report / plan
Code of conduct, risk
management, reporting