What does adverse human rights impact mean?
Under CSDDD, adverse human rights impact is similarly bounded — it covers impacts resulting from the abuse of one of the human rights listed in Part I, Section 1 of the Annex, which references international human rights instruments including the International Bill of Human Rights and ILO core conventions. Like the environmental counterpart, the legal trigger is not any human rights concern but specifically those tied to the enumerated instruments.
Official definitions by source
CSDDD
Directive (EU) 2024/1760 on corporate sustainability due diligence
an impact on persons resulting from: (i) an abuse of one of the human rights listed in Part I, Section 1, of the Annex to this Directive, as those human rights are enshrined in the international instruments listed in Part I, Section 2, of the Annex to this Directive; (ii) an abuse of a human right not listed in Part I, Section 1, of the Annex to this Directive, but enshrined in the human rights instruments listed in Part I, Section 2, of the Annex to this Directive, provided that: — the human right can be abused by a company or legal entity; — the human right abuse directly impairs a legal interest protected in the human rights instruments listed in Part I, Section 2, of the Annex to this Directive; and — the company could have reasonably foreseen the risk that such human right may be affected, taking into account the circumstances of the specific case, including the nature and extent of the company’s business operations and its chain of activities, the characteristics of the economic sector and the geographical and operational context;
Reference: Article 3, point c
View official source
Practical application
For supply-chain teams, this definition focuses CSDDD human-rights due diligence on a concrete set of risks: forced labour, child labour, unsafe working conditions, freedom of association, and similar issues rooted in the listed ILO and UN instruments. Mining supply chains — especially for battery minerals in cobalt, lithium, and mica — are among the highest-priority areas given documented risks in these sectors.
Minespider commentary
For Minespider, adverse human rights impact connects directly to the battery due diligence requirements of the EU Battery Regulation's Chapter VI, which shares similar risk categories. Companies with battery mineral supply chains are effectively operating under two parallel due diligence regimes — CSDDD and the Battery Regulation — with overlapping but not identical risk catalogues.
Common confusions
- Assuming CSDDD covers all human rights — the definition anchors to specific listed instruments, so coverage depends on which rights those instruments protect.
- Confusing CSDDD human rights due diligence with the UN Guiding Principles on Business and Human Rights (UNGPs) — CSDDD is partly inspired by UNGPs but creates binding legal obligations that go beyond the UNGPs' voluntary framework.
- Treating CSDDD human rights obligations as limited to direct operations — the Directive explicitly extends to upstream business partners and, in some cases, downstream value chain actors.
Related regulations