It can be challenging for businesses to understand how to comply with the new Corporate Sustainability Due Diligence Directive (CSDDD/CS3D) and broader Human Rights and Environmental Due Diligence (HREDD) requirements, particularly when addressing child labour in their value chains.

To support businesses in addressing these challenges responsibly, experts in the field of Business and Human Rights have developed this Note, which sets out 11 expectations aimed at raising awareness and providing legal guidance to support the effective and ethical implementation of CSDDD/CS3D and HREDD requirements.

The Note is intended to be a dynamic resource that evolves over time in light of field experience and stakeholder insights. The first version was published in 2025 and is available here. This second version further emphasises child-centred approaches that prioritise the best interests of the child, as well as the importance of responsible due diligence, collaboration, transitional measures, and continuous improvement.

If you would like to share insights, comments, or questions about the Note, or if you would like to become a signatory and support this project, please contact Mathilde Aboud at mathilde.aboud@gmail.com.

EXPERT NOTE ON CHILD LABOUR PREVENTION IN SUPPLY CHAINS – VERSION 2 (2026) 

Preamble

An estimated 138 million children worldwide remain engaged in child labour. While the eradication of child labour remains an urgent global objective under international law, experience demonstrates that the manner in which child labour is addressed is as important as the objective itself. The best interests of the child must be a primary consideration in all business actions concerning child labour, in accordance with Article 3 of the United Nations Convention on the Rights of the Child (CRC). Businesses must interpret their responsibilities in a manner that prioritises the rights, dignity, safety, development and voices of the child.

This Expert Note, which aims to contribute to the effective elimination of child labour in supply chains has been developed by an international group of experts in the Business and Human Rights community. It is a living document, intended to evolve in light of practical experience, stakeholder dialogue, and lessons learned in the field.

This Expert Note does not constitute a legal framework. Rather, it is intended as a tool to guide businesses when designing and implementing ongoing human rights and environmental due diligence (HREDD) in a manner that is more child-centred, context-sensitive, and aligned with the UN Guiding Principles on Business and Human Rights (Pillar 2 of the UNGPs).

Experience from multiple jurisdictions demonstrates that rigid or purely compliance-driven responses — including zero-tolerance approaches that immediately terminate supplier relationships or dismiss children from work without safeguards — may unintentionally expose children to more hazardous labour, deeper poverty, trafficking, or sexual exploitation.

For this reason, this Expert Note promotes a child-rights-based and transitional approach. Businesses are encouraged to::

• Address the root causes of child labour, including poverty, lack of access to education, and inadequate social protection;
• Avoid actions that may worsen children’s living conditions;
• Ensure that children’s views are heard and considered in decisions affecting them, consistent with Article 12 CRC;
• Support remediation strategies that strengthen access to education, livelihoods for families, and community resilience also recognizing the need to extend this principle to new and evolving contexts, such as digital and commercial environments;
• Pay special attention to cultural contexts in which child labour is linked to the exploitation of rightsholders such as indigenous and also traditional communities or socially vulnerable groups, racial and ethnic minorities, migrant populations, and refugees;
• Exercise leverage responsibly and collaboratively, recognizing that eradication of child labour is a process requiring sustained engagement with local communities, civil society and governments, both local and national, while avoiding as much as possible abrupt withdrawal.

Expectations From Businesses

1. All measures taken by businesses to address child labour must aim to respect and strengthen children’s rights including the right to have their best interests taken into account, to be heard, and their access to education and livelihood following a holistic approach.

2. Businesses shall implement Human Rights and Environmental Due Diligence (HREDD) paying special attention to child labour issues within the entire global value chain with a focus on the risks to children.

3. It is understood that the obligations of businesses do not require them to guarantee the outcome of no child labour throughout their supply chain. The expectation is one of continuous improvement. It requires businesses to identify child labour as much as possible, prioritize measures to prevent and address it where they have leverage or increase leverage. Businesses shall regularly evaluate their practices and make necessary adjustments to ensure effectiveness; and to transparently publish the outcome of their efforts, on an annual basis, to enable proper auditing and to facilitate the sharing of best practices. When concrete violations occur, businesses shall be deemed responsible to remediate the harm relative to their respective responsibility.

4. Businesses shall develop explicit internal policies on child labour and its reduction/elimination, and encourage their business partners to implement such policies, so that they are aligned with international standard(s) concerning matters related to (acceptable) child work and (forbidden) child labour.

5. Businesses shall integrate binding clauses in suppliers’ contracts, mandating agreement by both parties to Human Rights and Environmental Due Diligence (HREDD) standards, including the obligation to prevent, remedy and address child labour while incorporating measures that strengthen children’s access to education and livelihood. Contracts shall include an obligation to engage in responsible purchasing practices, that would cover their costs of executing HREDD, mechanisms for monitoring, and also corrective actions in case of non-compliance.

6. As purchasers in a value chain, businesses will contractually commit themselves to pay prices that ensure sustainability and allow suppliers to progressively raise such pay to the level of living wage and businesses shall demand that suppliers ensure that such pay increases benefit workers. Additionally, businesses will require that the suppliers consult with rightsholders about best remediation measures in case child labour is identified.

7. Businesses commit to adopt a holistic child rights approach, ensuring decent work and aim at ensuring a living wage for parents and caregivers, decent work for young workers (above the minimum legal working age), and family friendly workplace policies, and to regularly collaborate with stakeholders to address root causes, and contribute to strengthening social protection systems.

8. Where child labour does occur, businesses with the participation of States shall enable children to be part of remediation programs designed to strengthen their access to education and improve their livelihood, in line with children’s best interest. Businesses shall avoid adopting a dogmatic zero tolerance policy towards child labour, i.e. by merely expelling suppliers or children as this could result in additional harm to children or shift the problem to other sectors and suppliers. Businesses shall instead focus on addressing the root causes of child labour, putting the best interests of children first, including their right to be heard. This includes both access to education and improved economic security through strengthening social protection measures.

9. Businesses are expected to provide funding to develop country-specific policies/projects designed to improve the situation of children who have been involved in child labour. Such development shall be based primarily upon advice from local and international child labour experts.

10. Businesses shall analyse adverse human rights impacts caused by any exiting strategies and shall decide to exit only as a last resort. If and when businesses decide they have to exit a particular jurisdiction or terminate a business relationship, they will do so responsibly, taking into account the consequences for all rights holders.

11. Businesses shall engage in collaborations and meaningful engagement with various stakeholders (intergovernmental organizations, employer organizations, Chambers of Commerce, governments, non-governmental organizations, including local grassroots, industry associations, funders such as banks and investors, etc.) to develop policies addressing child labour, taking into account local contexts. Such collaboration may also support the effective implementation of these policies, including through concrete actions, monitoring mechanisms, and ongoing dialogue with relevant stakeholders.

Signatories:

Mathilde Aboud (Human Rights consultant, France)

Meriam Ben Boubaker (Directrice de contrôle de gestion et vice-présidente de l’International CFO Alliance et de MIZEN pour l’égalité des chances et la gouvernance-Tunisia)

Stéphane Brabant (Lawyer, France)

Martine Combemale (Ressources Humaines sans Frontières Director, France)

Piseth Duch (Business & Human Rights Lawyer,  Cambodia)

Karine Fettu (Fashion Theory, Hong Kong)

Alan Franklin (Professor, Canada)

Carolyn Franklin (Professor, Canada)

Elise Groulx Diggs (9 Bedford Row Chambers, USA-UK)

Dr. Pınar Kara (Lawyer & Cofounder of Minerva BHR, Turkey)

Caroline Omari Lichuma (Postdoctoral Researcher, Germany)

Sanjida Shamsher Elora (BHR Capacity Building & Assessment Expert, Sweden)

Martijn Scheltema (Pels Rijcken, Netherlands)

Daniel Schönfelder  (Lawyer, Germany)

Clara Serva (TozziniFreire Advogados, Brazil)

Sunny Sun (Lawyer, China)

Liesbeth Unger (Human Rights at Work Director, Netherlands)