Towards ‘greening’ trade? The environment in the French, German and EU supply chain laws

Abstract

The European Union (EU) recently adopted the Corporate Sustainability Due Diligence Directive (CSDDD), which its 27 member states must now transpose into national law. Starting in mid-2026, the Directive aims to encourage sustainable and responsible corporate behavior in global supply chains. France and Germany had already independently enacted their own national supply chain laws, the 2017 Loi de Viligence (LdV) and the 2021 Lieferkettensorgfaltspflichtengesetz (LkSG). This article examines the extent to which the new supply chain legislation addresses environmental burden shifting through international trade. We develop an analytical framework on scope, procedure and enforceability with respect to the environment. To do so, we identify the central demands of environmental non-governmental organizations (ENGOs), drawing on their campaign materials, expert interviews, and participant observation at stakeholder events. Our results show a regulatory ’race to the top’ with ‘bends’ in the sense that the German law lags behind the French law in some aspects, but the new CSDDD is the most precise and comprehensive in all aspects of supply chain legislation. We conclude that the stage is set for the ’greening’ of international trade.