German supply chain due diligence act

The Lieferkettensorgfaltspflichtengesetz, the LkSG, is the German supply chain due diligence act. It entered into force on 1 January 2023 for companies with 3,000 or more employees in Germany. From 1 January 2024 the threshold is 1,000 employees in Germany. The act is in force. The consolidated text on gesetze-im-internet.de is the version used here.

Section 10 of that consolidated text still requires an annual public report on the due diligence the company carried out. Check the same text for any later amendment of that duty. BAFA, the federal office that supervises the act, publishes an overview of the regime. For as long as section 10 requires the report, companies in scope should treat it as part of the act.

Due diligence covers the company’s own operations and its supply chain, with a stronger duty on direct suppliers and a risk-based duty further along the chain. The subject is the human-rights and environmental risks listed in the act. A textile or apparel company with 1,000 employees in Germany is in scope even when the factories are abroad. Companies below the threshold are not regulated by the act directly. They are often asked for data by customers that are in scope. That pressure is contractual. It is not the same as being the company BAFA supervises.

The CSDDD will overlap with this act once Germany transposes it. Transposition is due by 26 July 2028, and the CSDDD applies from 26 July 2029. The existence of the directive does not repeal the LkSG. Until transposition, the LkSG remains the national statute for companies inside its employee threshold. The two instruments use different thresholds and different duties. A company can fall under the LkSG and stay outside the amended CSDDD, because 1,000 employees sits well below the CSDDD line of more than 5,000 employees and €1.5 billion in turnover.

Germany does not have a separate textile EPR statute in force beside the LkSG. The Union deadline for national textile and footwear schemes is 17 April 2028, under Directive (EU) 2025/1892. That is a waste-law duty, described on the Union EPR page, not a section of the LkSG.

Companies with 1,000 or more employees in Germany have been in scope since 1 January 2024. From 1 January 2023 the threshold was 3,000. Suppliers below the line can still receive questionnaires. BAFA supervises the companies in scope.

Apparel brands and retailers with enough employees in Germany have to look at spinning, dyeing and sewing sites, not only at a German head office. The act is about human-rights and environmental risks in the supply chain. It is not a textile take-back fee.

JOYNN can keep the commercial chain and the facility data a company uses when it documents suppliers for the LkSG, or when it answers a customer that is in scope. It does not file the section 10 report with BAFA, it does not decide whether a risk is a breach, and it does not make anyone compliant. JOYNN is not legal advice. The JOYNN Index can organise audit criteria. It is not a BAFA finding.