Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 (Conflict Minerals); SEC Rule 17 CFR Parts 240 and 249b

The Green Guides set out how the FTC will interpret Section 5 of the FTC Act when reviewing environmental marketing claims, covering general principles such as substantiation and qualification, plus specific claim types including recyclable, compostable, degradable, carbon offsets and renewable energy. Marketers who do not follow the Guides risk deception findings.

Enforcement

Guidance (interpreting Section 5 of the FTC Act)

Effective date

Current text issued October 2012; revision date TBD

Covered entities

Any marketer making environmental claims about a product, package or service in US commerce

Importers must rebut the presumption by clear and convincing evidence that goods were not made wholly or in part with forced labour, including full supply chain tracing, due diligence, and responses to CBP requests for information. CBP detains, excludes, or seizes non-compliant shipments and publishes operational guidance and the FLETF strategy.

Enforcement

Mandatory

Effective date

23 December 2021 (enacted); 21 June 2022 (rebuttable presumption); UFLPA Entity List updated periodically (latest: 43 entities added effective 3 August 2026, 187 entities listed)

Covered entities

Any importer of record bringing goods into the United States. Goods mined, produced, or manufactured wholly or in part in the Xinjiang Uyghur Autonomous Region, or by entities on the UFLPA Entity List, are presumed to be made with forced labour and barred under 19 U.S.C. § 1307.

Directive requiring very large EU and non-EU companies to identify, prevent and address adverse human rights and environmental impacts in their own operations, their subsidiaries' operations and their chains of activities. Omnibus I (Directive (EU) 2026/470) raised the thresholds, deleted the climate transition plan obligation, removed the EU-wide civil liability rule (liability now rests on national law), and capped fines at 3% of net worldwide turnover.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2028. National measures apply to all in-scope companies from 26 July 2029; Article 16 reporting applies for financial years starting on or after 1 January 2030.

Covered entities

EU companies with more than 5,000 employees on average and more than EUR 1.5 billion net worldwide turnover, or ultimate parents of groups reaching those thresholds. Non-EU companies with more than EUR 1.5 billion net turnover in the EU in the financial year before the last. Separate thresholds apply to franchising and licensing groups (royalties above EUR 75 million plus turnover above EUR 275 million).

Companies in scope must identify, prevent, and remediate human rights and environmental risks in their own operations and direct suppliers, with risk-based duties extending to indirect suppliers when substantiated knowledge arises. BAFA monitors compliance, can issue orders, and impose fines up to EUR 8 million or 2 percent of average annual turnover (where turnover exceeds EUR 400 million).

Enforcement

Mandatory

Effective date

1 January 2023 (companies with 3,000+ employees in Germany); 1 January 2024 (1,000+ employees in Germany)

Covered entities

Companies with their head office, principal place of business, administrative seat, or registered branch in Germany and at least 1,000 employees in Germany (3,000+ in 2023). Includes German branches of foreign companies.

Covered enterprises must conduct human rights and decent working conditions due diligence aligned with the OECD Guidelines, publish an annual account of their efforts by 30 June, and respond in writing within three weeks to public information requests. The Consumer Authority supervises through guidance, decisions, and enforcement penalties.

Enforcement

Mandatory

Effective date

1 July 2022; first annual due diligence accounts due by 30 June 2023

Covered entities

Larger Norwegian enterprises and foreign enterprises selling goods or services in Norway that are tax-liable in Norway. Companies must meet two of three thresholds: NOK 70 million sales revenue, NOK 35 million balance sheet total, 50 FTE employees.

In-scope parent and ordering companies must establish, publish, and effectively implement a vigilance plan covering risk mapping, supplier and subcontractor assessment, mitigation actions, an alert mechanism, and a monitoring scheme addressing human rights, health and safety, and environmental harm across the group and established business relationships. Any party with standing can give formal notice and, after three months of non-compliance, seek a court injunction and damages.

Enforcement

Mandatory

Effective date

27 March 2017; first vigilance plans required for FY2017

Covered entities

French-headquartered companies that, for two consecutive years, employ at least 5,000 employees in France (parent and direct/indirect subsidiaries) or at least 10,000 employees worldwide.