The Netherlands is preparing supply-chain due diligence rules for very large companies. The draft law will not cover every business, but customer contracts, questionnaires and record requests may reach smaller suppliers first.
Why this matters
The draft Dutch law would implement the EU CSDDD. It targets companies with 5,000 employees and €1.5 billion turnover. Dutch transposition is due by 26 July 2028. Compliance is expected from 26 July 2029. The bill remains in preparation. Large customers may request product origins, labor conditions, environmental risks and subcontractor details. Missing records can delay renewal. A broad declaration can exceed the evidence in a supplier file.
Example
A wholesaler receives new terms from a major customer. The customer asks for each product’s origin and details about subcontractors. Its file holds invoices, product specifications and some certificates. It cannot verify every business further down the chain. Signing the declaration without limits could create an unsupported promise. Refusing it outright could affect renewal. The wholesaler can confirm what its file shows, identify gaps and agree how updates will be handled.
XTROVERSO tips
- Separate the law from the contract. Check what the law directly requires, what the customer requests and what your records support. These are different questions. Read every declaration before signing it.
- Build one supplier file. Keep contracts, invoices, purchase orders, product details, origin information and certificates together. Name the person responsible and record when the file was last checked.
- Check public claims against proof. Match website, packaging and sales claims to the documents you hold. Narrow any wording that covers more products, suppliers or periods than the evidence supports.
- Count the cost of extra work. Audit rights, questionnaires and regular reports take staff time. Check the effect on price, planning and margin. Discuss scope and frequency when the work is substantial.
- Set clear update triggers. Review the file when a supplier, producer, route, subcontractor or certificate changes. Record the change and notify customers where the contract requires it.
Need help checking supplier terms, records or a declaration before signing? Our team can review the business risk with you
The data, sourcing, and analysis behind this article were conducted by Paolo Maria Pavan. AI was not used to identify sources, build the factual basis, or produce the analytical judgment contained here. AI was used only as a drafting aid. The final English text was personally reviewed, edited, and approved by Paolo Maria Pavan before publication.
References
- ACM — Toets ontwerpwetsvoorstel Internationaal Verantwoord Ondernemen
- Overheid.nl — Wetgevingskalender en voortgang wetsvoorstel
- Rijksoverheid — Internationaal verantwoord ondernemen en CSDDD
- ACM — Voorbereiding toezicht op internationale ketenverantwoordelijkheid
- ACM — Strengere eisen aan duurzaamheidsclaims


