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Supply Chain

US Lacey Act: Import Declaration for Plant Products

In 2023 and 2024, US Customs and Border Protection stepped up seizures of imported wood products with incomplete or inaccurate Lacey Act declarations — including multiple container-loads of hardwood flooring and furniture from Southeast Asia. CBP's enforcement focus has shifted from high-profile criminal prosecutions to routine port-level verification: if the species, country of harvest, or quantity on your PPQ 505 form does not match the shipment, the goods are detained, and the importer of record bears the cost of storage, re-export, or destruction.

The US Lacey Act (16 U.S.C. §§ 3371–3378) was originally enacted in 1900 to combat wildlife trafficking. The 2008 amendment extended it to plants and plant products, creating a mandatory import declaration regime that covers an enormous range of goods — from raw timber to finished furniture, paper, and musical instruments. On the Sustalium platform, we see Lacey Act declarations becoming a more frequent request in the furniture and construction materials supply chains, as US retailers strengthen their import compliance programs.

SMETA Audit Guide: Sedex Social Compliance

Sedex reports over 75,000 members across 180 countries, with more than 340,000 SMETA audits conducted globally. The most common non-compliance findings — working hours, wages below the legal minimum, and inadequate health and safety controls — appear consistently across the textile, electronics, and agriculture sectors. Under the UK Modern Slavery Act, brands like Marks & Spencer, Tesco, Unilever, and Primark explicitly cite SMETA audit programs in their public modern slavery statements, and the EU's CSDDD now extends similar due diligence obligations across the entire bloc. For a supplier, a lapsed or missing SMETA report increasingly means automated deselection from buyer procurement systems — often before a human reviewer ever sees the application.

SMETA (Sedex Members Ethical Trade Audit) is the most widely used social compliance audit methodology in the world. It assesses working conditions across labor standards, health and safety, environmental management, and business ethics. For suppliers in apparel, textiles, electronics, furniture, and FMCG, a current SMETA audit report is often the price of admission to the Western buyer market. On the Sustalium platform, we see the same buyer who requests a CE Declaration of Conformity now routinely asking for the most recent social audit — because procurement teams are being measured on supply chain risk, not just product compliance.

French Duty of Vigilance: LdV Supply Chain Law

Since the French Duty of Vigilance Law came into force in 2017, NGOs and affected communities have filed multiple high-profile lawsuits — against TotalEnergies over its Tilenga oil project in Uganda and Tanzania, against EDF over a wind farm affecting indigenous communities in Mexico, and against BNP Paribas over fossil fuel financing. In 2023 alone, four new LdV cases were filed in French courts. None resulted in an operational suspension order, but each forced the defendant company to publicly disclose and — in some cases — substantially revise its vigilance plan. The law is no longer a dormant obligation. It is being actively litigated.

The French Duty of Vigilance Law (Loi de Vigilance — LdV, Law No. 2017-399) was the first mandatory human rights and environmental due diligence law in Europe. It requires large French companies to establish, publish, and implement a vigilance plan covering their own operations, those of their subsidiaries, and those of their suppliers and subcontractors. On the Sustalium platform, we now hear from French procurement teams asking suppliers to provide structured ESG and supply chain data specifically to feed into the parent company's vigilance plan — and if a supplier cannot produce the data, they get replaced.

Supplier Onboarding Compliance Software

Manually onboarding a new supplier means chasing emails, verifying certificates one by one, re-entering data into spreadsheets, and hoping nothing slips through the cracks. It is slow, error-prone, and scales poorly. Supplier onboarding compliance software solves this by replacing manual workflows with automated data collection, risk scoring, and document verification — all in one place.

Canada Bill S-211 Compliance Software

Canada Bill S-211 — the Fighting Against Forced Labour and Child Labour in Supply Chains Act — came into force on January 1, 2024. It requires many businesses and government institutions to file an annual report with the Minister of Public Safety detailing the steps they have taken to prevent and reduce the risk of forced labour and child labour in their supply chains. For procurement, legal, and sustainability teams, the reporting burden is real — and the penalties for non-compliance can be severe. Sustalium's Canada Bill S-211 compliance software turns this annual headache into a guided, automated workflow that maps directly to Public Safety Canada's expectations.

How to Answer a CSDDD Supplier Due Diligence Request

If you've noticed your customers' procurement questionnaires getting longer and more demanding, you're not imagining it. That's the CSDDD effect: large companies subject to the Corporate Sustainability Due Diligence Directive need data from every supplier in their chain of activities — including you, regardless of your size.

Here's the thing most suppliers miss: responding well to these questionnaires isn't just about keeping the customer happy. It's a competitive advantage. Suppliers who answer in days instead of weeks, who have their data organised and accessible, consistently rank higher in procurement evaluations.

CSDDD: EU Corporate Due Diligence Rules

The CSDDD (Directive 2024/1760, also called CS3D) is the regulation that turns voluntary ESG commitments into legal obligations with teeth. If your company has >1,000 employees or >€450M turnover, you're legally required to identify, prevent, and remediate human rights and environmental harms in your supply chain — and if you don't, you can be sued.

It closes a gap that's existed for decades: companies could talk about ethical supply chains without any legal framework forcing them to actually do something about problems they found. CSDDD changes that.

EU Deforestation Regulation (EUDR): Enforcement

The EU Deforestation Regulation (2023/1115) is in full enforcement, and it's already reshaping global supply chains. If you deal in cattle, cocoa, coffee, oil palm, rubber, soya, or wood, you need a Due Diligence Statement for every shipment — backed by geolocation coordinates down to the plot level. No exceptions, no phase-ins for small operators.

Most companies underestimate how hard the geolocation requirement is. Your supplier in Côte d'Ivoire needs to provide plot-level GPS coordinates that match satellite imagery. If they can't, your shipment doesn't clear customs.

German Supply Chain Act (LkSG) Compliance Software

If you've got 1,000+ employees in Germany, the LkSG already applies to you — and BAFA isn't messing around. Fines can hit €8 million or 2% of annual turnover, and the seven due diligence obligations (§4–§10) cover everything from risk analysis to complaints procedures to annual BAFA reporting.

Here's the thing: LkSG compliance isn't a one-time project. It's an annual cycle of risk analysis, preventive measures, documentation, and reporting. LkSG compliance software won't replace the human rights expertise you need, but it'll stop you from drowning in paperwork while BAFA asks for your records.

What to Ask Suppliers Before They Get You Fined

If your supplier uses forced labor, the goods are seized at the US border — and you are the importer of record. If your supplier discharges untreated wastewater, your CSRD disclosure is inaccurate, your CSDDD due diligence is incomplete, and your buyer drops you. If your supplier's SMETA audit is expired by six weeks, the procurement system deselects you automatically — and the buyer does not ask why. The legal violation is the supplier's. The commercial and legal consequence is yours.

The regulatory frameworks that impose cascading liability — making a buyer legally responsible for what happens in their supply chain — are multiplying globally. The German Supply Chain Act (LkSG), the EU's CSDDD, the US Uyghur Forced Labor Prevention Act (UFLPA), the UK and Australian Modern Slavery Acts, the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act — each of these creates a legal obligation for the buyer to know what is happening in their supply chain and to act on what they find. And each of them starts with the same operational question: what do you ask your suppliers — and what documentation do you demand — before you place the order?