Supply-chain due diligence and climate policy were long spoken of together. As of July 2026 the picture has changed: the climate limb of the due diligence legislation has largely been withdrawn, while the actual cost attached to carbon has risen through border carbon rules and customer contracts. This note separates the two movements and sets out what applies to Turkish suppliers today.
Climate within the due diligence framework: where things stand
The German LkSG has no climate dimension. The words climate, greenhouse gas and Paris Agreement do not appear in the statute at all; its definition of environmental risk is a closed list of eight prohibitions drawn from the Minamata, Stockholm POPs and Basel Conventions (§ 2(3)). Those are chemicals and waste headings, not climate headings.
On the Directive side, the climate transition plan obligation has been repealed. In the adopted CSDDD it sat in Article 22; the Omnibus I directive adopted in February 2026 ((EU) 2026/470, Art. 4(16)) removed it from the text entirely with the words “Article 22 is deleted”. Because the Directive first applies on 26 July 2029, that article will never have applied to any company.
Two frequently repeated errors are worth correcting here. The first is citing the climate plan obligation as “Article 15 of the Directive”: in the adopted text Article 15 is headed Monitoring, and that number belongs to the 2022 Commission proposal. The second is the statement that the Directive ties directors’ variable remuneration to fulfilment of the climate plan; that provision existed only in the 2022 proposal (Art. 15(3)) and never entered the adopted text.
So where did the climate obligation go?
It did not disappear; it moved. For Turkish suppliers, climate now arrives through three concrete channels.
The first, and the most concrete, is border carbon pricing. The EU Carbon Border Adjustment Mechanism (CBAM) has been running in its definitive regime since 1 January 2026 and creates a real per-product cost for exports of cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. Here climate is not a reporting heading — it is a priced item.
The second is data requests arriving through reporting. EU customers within the scope of the Corporate Sustainability Reporting Directive (CSRD) must report on their value chains, and the regime for reporting on a transition plan a company already has is unaffected by the deletion of Article 22 from the CSDDD. The request reaches the supplier through contracts and annual questionnaires.
The third is the contract. Even where legislation has been simplified, buyers continue to ask for emissions data, targets and verification because of their own commitments. A contractual obligation binds independently of a statutory one.
The critical point for Turkish suppliers
It would be a mistake to read the legislative simplification as “the climate chapter is closed”. What was removed from the CSDDD concerned the company’s own plan; the mechanisms that ask a supplier for data — the carbon border mechanism and customer contracts — remain in place, and are becoming more demanding.
In practice the right structure is to hold climate data inside the ESG and sustainability workstream as a single data set: shared data by site and supplier, one risk methodology, and consistent statements across the policy declaration, the annual report and any sustainability reporting. That structure answers the request whichever regime happens to be in force.
