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The expectation that companies consider the human rights implications of their purchasing decisions has been embedded in international standards for over a decade.
What is changing is that those expectations are now being written into law. For procurement, sustainability, and compliance professionals, understanding that legislative landscape – and how to navigate it – is increasingly urgent.
This page maps the key legislative and standards frameworks that bear on responsible purchasing, explains how they relate to each other, and shows how the Common Framework for Responsible Purchasing Practices (CFRPP) can help your business meet its obligations - by offering companies a structured set of principles and expectations that can guide the development of purchasing practices consistent with human rights due diligence.
Companies must review their own purchasing practices as part of their human rights due diligence (HRDD). For a clear shared understanding of what this looks like in practice, use the Purchasing Practices HRDD (PP-DD) Framework.
Other pages in ETI's responsible purchasing practices cluster:
Responsible purchasing practices: what they are and why they matter
How to implement responsible purchasing practices
Responsible purchasing practices by sector
RPP is not a new idea: the international standards foundation
The case for responsible purchasing has been made consistently by international bodies for many years. The UN Guiding Principles on Business and Human Rights (UNGPs), endorsed by the UN Human Rights Council in 2011, established that companies have a responsibility to respect human rights across their value chains. The UNGPs explicitly highlight purchasing decisions as a source of potential harm: where buyers do not consider how their commercial decisions affect suppliers' ability to uphold labour standards, they risk contributing to adverse human rights impacts.
The OECD Guidelines for Multinational Enterprises reinforce this position. OECD sector-specific due diligence guidance – particularly for the garment and footwear sector – recommends that businesses implement controls to prevent contributing to harm through their purchasing practices. The ILO Multinational Enterprises (MNE) Declaration similarly places responsible business conduct, including the purchasing relationship, within the framework of companies' responsibilities to workers throughout their supply chains.
These standards have shaped the development of ETI's Common Framework and continue to provide the conceptual foundation on which legislation is now built. When companies or legislators talk about responsible purchasing as a due diligence requirement, they are drawing on a body of international norms that has been developing for well over a decade.
How legislation is codifying what standards long required
The shift from voluntary standards to binding legislation is significant in practical terms, but it does not represent a change in the underlying expectations. Companies that have been taking responsible purchasing seriously for years will find that the legislative requirements largely reflect what good practice already looks like. For companies that have not yet engaged seriously with their purchasing practices, legislation provides both a prompt and a framework for action.
The legislative landscape affecting responsible purchasing is not a single directive but an overlapping set of instruments, operating at EU level and in national markets, each bearing on different aspects of the buyer-supplier relationship. Understanding how they interact matters for companies operating across multiple markets and sectors.
The CSDDD: purchasing practices as a due diligence obligation
The EU Corporate Sustainability Due Diligence Directive (CSDDD), adopted in 2024, is the most significant piece of legislation for responsible purchasing. It requires companies in scope to identify, prevent, mitigate, and address adverse human rights and environmental impacts across their operations and supply chains. Purchasing practices sit explicitly within the scope of those obligations.
The Directive makes clear that companies must review their own operations as part of due diligence, and that purchasing practices and strategies should not contribute to adverse impacts. This is a meaningful shift: it places the buyer's commercial behaviour within the frame of human rights compliance, not just supplier conduct. Companies cannot fulfil their CSDDD obligations through supplier audits and codes of conduct alone if their own buying decisions are simultaneously creating conditions for harm.
Each of the five CFRPP principles maps to specific CSDDD obligations. Integration and reporting corresponds to the Directive's requirements to embed due diligence into company strategy and decision-making. Equal partnership reflects the Directive's emphasis on meaningful stakeholder engagement and shared responsibility with suppliers. Collaborative production planning, fair payment terms, and sustainable costing each address purchasing practices that the Directive identifies as potential sources of adverse impact.
The Omnibus proposal of February 2025 introduced significant changes to the CSDDD, narrowing the scope of due diligence for many companies and adjusting timelines. However, the Omnibus proposal left the requirements relating to responsible purchasing practices unchanged. The obligation to address purchasing behaviour as part of due diligence remains in place regardless of how the Omnibus revisions are finalised. ETI's detailed mapping of the CFRPP against the CSDDD is available as a reference tool for companies navigating these requirements: see our resource on RPP in European legislation.
Beyond the CSDDD: other legislation that affects purchasing practices
The CSDDD is not the only instrument that matters. A number of other legislative frameworks – at EU level and in individual markets – create obligations that bear directly on how companies conduct their purchasing relationships.
The EU Unfair Trading Practices Directive (UTP) prohibits a defined list of unfair commercial practices in business-to-business food supply chain relationships, including late payment, last-minute order cancellations, and unilateral changes to contracts. Member states have transposed the Directive into national law, and enforcement is ongoing across the EU. For food sector buyers, UTP compliance and responsible purchasing practice improvement are closely related.
The UK Groceries Supply Code of Practice (GSCOP) applies to large grocery retailers in the UK and prohibits a similar range of unfair practices in their relationships with direct suppliers. GSCOP has been in force since 2010 and is enforced by the Groceries Code Adjudicator. It is referenced directly in the CFRPP food framework as a relevant standard for payment and costing practices.
The EU Forced Labour Regulation (EUFLR), which came into force in 2024, prohibits the placing and making available on the EU market of products made with forced labour. While the EUFLR operates through a product prohibition mechanism rather than a due diligence framework, irresponsible purchasing practices – excessive price pressure, unrealistic lead times, last-minute changes – are consistently identified as structural drivers of forced labour risk. Addressing purchasing practices is therefore a meaningful preventive measure to reduce forced labour risk and support compliance with the EUFLR, as well as under the CSDDD.
National-level legislation in EU member states – including the German Supply Chain Due Diligence Act (LkSG) and the French Duty of Vigilance Law – preceded the CSDDD and contain their own purchasing-related obligations. Companies already operating under these regimes will find significant overlap with CSDDD requirements as transposition proceeds.
Practical steps for navigating the legislative landscape
For procurement, sustainability, and compliance teams, the breadth of this legislative landscape can feel daunting. A few practical principles help to organise the work.
Start with your own purchasing practices. The CSDDD, the UTP, GSCOP, and the EUFLR all point in the same direction: buyers need to understand how their commercial decisions affect suppliers and workers. A structured review of existing purchasing practices – using the CFRPP as a reference – is the logical first step, and provides evidence for both internal governance and external reporting.
Engage suppliers as partners. The legislative frameworks consistently emphasise that compliance is not something companies can impose on suppliers. Meaningful engagement – gathering supplier feedback, sharing the results, and developing improvement plans together – is both a legal expectation and a practical necessity for durable change.
Build purchasing practice improvement into due diligence processes. RPP is not a separate workstream from HRDD. It is one of the most important levers within a company's due diligence framework, because it addresses root causes rather than symptoms. Integrating RPP into existing HRDD processes avoids duplication and strengthens both.
Keep up with a fast-moving landscape. The Omnibus proposal is still being negotiated. National transposition of the CSDDD is ongoing across EU member states. The EUFLR enforcement mechanisms are developing. ETI monitors these developments and provides regular updates for member companies.
What non-compliance looks like – and the risks
The consequences of failing to address purchasing practices as part of due diligence will depend on which legislative instruments apply to a given company. Under the CSDDD, companies that fail to implement adequate due diligence – including in relation to purchasing practices – face civil liability for harms they caused or contributed to, as well as administrative penalties. Under the EUFLR, products associated with forced labour can be prohibited from the EU market. Under the UTP and GSCOP, specific unfair practices can trigger enforcement action and financial penalties.
Beyond the legal risks, the reputational consequences of purchasing practices that cause harm to workers are significant and increasingly visible. Supplier perspectives on buyer behaviour are increasingly being gathered and published – by ETI, by Better Buying, and by other initiatives – making it harder for irresponsible purchasing to remain invisible. Companies that have not yet engaged seriously with their purchasing practices face growing exposure on multiple fronts.
Get practical support on RPP and compliance
If your business needs to meet its obligations across the CSDDD, EUFLR, UTP, or other frameworks, ETI can help you build a structured, credible approach.
For a broader introduction to the due diligence landscape: Human rights due diligence