Soft Empire or Shared Responsibility? Europe’s Human‑Rights Due Diligence

In 2013, the Rana Plaza garment factory in Bangladesh collapsed, killing more than 1,100 workers and injuring thousands more. The building housed suppliers producing clothes for global fashion brands, including many selling into European markets. Despite visible cracks the day before the disaster, workers were ordered back to work. Rana Plaza became a symbol of the gulf between glossy corporate codes of conduct, and the dangerous reality faced by workers in global supply chains.

More than a decade on, voluntary initiatives have improved some practices, but they have not eliminated systemic risks. As a result, Europe is turning human rights due diligence into a legal duty. Under the UN Guiding Principles on Business and Human Rights (UNGPs), companies are expected to carry out human rights due diligence. This expectation has inspired laws such as France’s Duty of Vigilance Law, and the EU’s Corporate Sustainability Due Diligence Directive (CSDDD), which applies to large EU companies with more than 1,000 employees and over €450 million in worldwide net turnover, non-EU companies with more than €450 million in turnover generated within the EU, and certain large franchise and licensing businesses.

This is a logical extension of a familiar pattern. The "Brussels Effect," as defined by scholars, is when EU regulations tend to become de facto global norms as businesses adapt globally to comply with EU regulations to meet EU regulatory requirements, especially when serving the EU’s large internal market. A classic example is the General Data Protection Regulation (GDPR), whose rules have influenced data-protection laws, policies and practices well outside Europe. CSDDD extends this dynamic: in-scope businesses will increasingly need due diligence procedures that satisfy EU environmental and human rights standards if they wish to sell into the bloc.

However, the more interesting questions are: who designs the rules, who bears the costs, and who really benefits when Brussels regulates the world’s supply chains? The mandatory human rights due diligence system in Europe shapes labour and environmental norms well beyond its borders by using EU market power. This may appear as a new kind of regulatory colonialism, or as long-overdue accountability. How CSDDD performs in the Global South will have a significant impact on whether it functions as a soft empire, or as solidarity.

From one angle, the CSDDD promises to raise the standard globally by making it harder for companies to ignore abuses in distant factories and fields. Under both the UNGPs and emerging national and EU legislation, firms that systematically identify and address risks, and that can evidence the actions taken, are both more accountable when harms occur and more credible when responsible conduct is demonstrated. Trade unions, affected communities, and civil society organisations in supplier countries can also draw on these legal obligations and the documentation they produce as leverage in negotiations and litigation.

From another angle, legal standards and technical guidance are primarily drafted in EU institutions, member state ministries and European expert networks; actors in Asia, Africa and Latin America often encounter them only once they are already agreed. Suppliers in Dhaka, Nairobi or Bogotá typically usually encounter CSDDD as a result of new contract provisions and audit requirements issued by European clients. Small and medium-sized businesses in supplier nations bear a disproportionate share of compliance expenses, including new systems, paperwork, training, and audits. These businesses sometimes lack access to funding and legal knowledge. Larger, better-capitalised suppliers, including those closer to European ownership, are better placed to adapt, potentially accelerating consolidation in global value chains.

Stakeholders in the Global South therefore have a variety of opinions. Building on past experiences, some labour activists applaud EU-level mHRDD as "finally a lever" against large businesses. Others oppose a "Designed in Brussels, implemented in Dhaka" strategy in which providers have no control over the standards themselves and are forced to abide by remote regulations, or face exclusion.

Decisions on implementation will be crucial. European companies and policymakers must combine legal requirements with more equitable purchasing practices to prevent "compliance colonialism." This includes offering longer-term contracts that reward higher standards, sharing the costs of audits and remediation, and involving local unions, communities, and suppliers in risk assessments and solutions. When implemented properly, the directive may become a tool for collaborative problem-solving instead of one-sided control.