Submission to the European Commission on the CSDDD Guidelines

August 14, 2026

The Coalition to End Forced Labour in the Uyghur Region (the “Coalition”) welcomes the opportunity to contribute to the European Commission’s development of Guidelines under the Corporate Sustainability Due Diligence Directive (“CSDDD”).

Due diligence in state-imposed forced labour contexts cannot be treated as ordinary supplier compliance. The Coalition’s expertise is specifically related to systemic, state-sponsored Uyghur forced labour, and the comments in this submission are not necessarily intended to be applicable to all other adverse impacts and geographies covered by the CSDDD. Where our recommendations draw on the Uyghur Region as an illustrative case, they reflect patterns of state-imposed coercion that the Guidelines should be equipped to address wherever they arise. This submission concerns how the Guidelines should apply to companies within the CSDDD’s scope as narrowed by Directive (EU) 2026/470; it does not take a position on that scope reduction itself.

Read the full submission here.

Photo by Alexandre Lallemand on Unsplash