Pass EU Diligence on the First Try: What to Show, How to Prove

By Aparna Vinod September 12, 2025

For Indian businesses exporting to Europe or working with EU-based buyers, sustainability compliance is no longer optional—it's the price of entry.

European buyers are conducting increasingly rigorous due diligence on their supply chains, driven by new regulations that hold them legally accountable for environmental and social risks. If you can't demonstrate compliance, you risk losing contracts—or being dropped as a supplier entirely.

The Big 4 EU Regulations You Need to Know

1. CSRD (Corporate Sustainability Reporting Directive)

Requires large EU companies to report detailed sustainability information—including data from their suppliers. If you supply to covered companies, expect requests for:

  • Carbon footprint data (Scope 1, 2, and 3)
  • Labor practices and human rights policies
  • Environmental impact assessments
  • Governance and ethics documentation

2. CSDDD (Corporate Sustainability Due Diligence Directive)

Mandates that companies identify, prevent, and remediate adverse human rights and environmental impacts throughout their value chains. This means EU buyers must:

  • Map their entire supplier network
  • Conduct risk assessments on suppliers
  • Verify corrective actions when issues are found
  • Maintain evidence of due diligence

3. CBAM (Carbon Border Adjustment Mechanism)

Starting in 2026, CBAM will impose carbon tariffs on imports of carbon-intensive goods like steel, cement, aluminum, fertilizers, and electricity. If you export these products, you must:

  • Calculate embedded carbon emissions accurately
  • Report emissions quarterly
  • Purchase CBAM certificates to offset emissions
  • Demonstrate carbon reduction efforts

4. EUDR (EU Deforestation Regulation)

Prohibits placing products on the EU market if they're linked to deforestation or forest degradation after December 2020. Applies to:

  • Cattle, cocoa, coffee, oil palm, rubber, soy, wood
  • Derived products (leather, chocolate, furniture, paper, etc.)

You must provide geolocation data proving materials weren't sourced from deforested land.

The Evidence Checklist: What Buyers Will Ask For

Policies & Governance

  • Code of Conduct: Written standards for ethical behavior
  • Health & Safety Policy: Documented workplace safety protocols
  • Environmental Policy: Commitment to environmental protection
  • Human Rights Policy: No forced labor, child labor, discrimination
  • Supplier Code of Conduct: ESG requirements cascaded to your suppliers
  • Whistleblower Mechanism: Anonymous reporting channel

ESG & Carbon Data (12 Months)

  • Energy consumption (kWh) split by source
  • Water withdrawal and discharge records
  • Waste generation and disposal logs
  • GHG emissions (Scope 1, 2, and ideally Scope 3)
  • Safety incident logs (Lost Time Injury Frequency Rate)
  • Employee demographics (gender, contract type)

Supply-Chain Controls

  • Supplier list: Tier-1 (and ideally Tier-2) mapping
  • Risk assessment: Environmental and social risk screening
  • Traceability: Material origin documentation
  • Audit reports: Third-party supplier audits (if applicable)

Certifications (Helpful but Not Always Required)

  • ISO 14001 (Environmental Management)
  • ISO 45001 (Occupational Health & Safety)
  • SA8000 (Social Accountability)
  • FSC/PEFC (Forestry), RSPO (Palm Oil), etc.

Remediation Proof

  • Grievance register: Complaints logged and resolved
  • CAPA logs: Corrective and preventive actions taken

Build to Sustain's Three-Phase Approach

We help Indian exporters pass EU due diligence through a structured, evidence-based process:

01
Phase 1: Assess

Gap analysis against EU requirements. We identify what's missing, what needs improvement, and prioritize based on buyer expectations and regulatory timelines.

02
Phase 2: Build

Develop policies, establish data collection systems, map supply chains, calculate carbon footprints, and train your teams on documentation and evidence management.

03
Phase 3: Verify & Convert

Package your evidence into audit-ready formats. We help you respond to buyer questionnaires, prepare for audits, and maintain ongoing compliance.

"EU compliance isn't about perfection—it's about proof. Show you've identified risks, implemented controls, and track progress. That's what passes due diligence."

Don't Wait Until You're Asked

The buyers conducting diligence today are the ones you want to keep tomorrow. Start building your evidence base now—before the questionnaire lands in your inbox.

Our EU Diligence Readiness Assessment identifies exactly what you need to prepare, in what order, and how to present it effectively.

Get EU-Ready
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