Uyghur Forced Labor Prevention Act, Public Law No. 117-78

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

Issuers must conduct a reasonable country of origin inquiry, file an annual Form SD, and where minerals may originate in the Democratic Republic of the Congo or an adjoining country and are not from recycled or scrap sources, conduct supply chain due diligence under the OECD Guidance and file a Conflict Minerals Report. Since 2017 SEC staff has not recommended enforcement of the independent private sector audit or DRC-conflict status conclusions.

Enforcement

Mandatory

Effective date

First reports required for calendar year 2013 (Form SD filed by 31 May 2014); annual filings continue. 2017 staff guidance partially limits enforcement.

Covered entities

SEC-registered issuers (domestic and foreign private issuers) for which conflict minerals (tantalum, tin, tungsten, gold) are necessary to the functionality or production of a product they manufacture or contract to manufacture.

Directive requiring large EU and non-EU companies to identify, prevent, and remedy adverse human rights and environmental impacts in their operations and value chains, and to adopt a climate transition plan. Scope and timelines were revised by the 2025 Omnibus package and Directive (EU) 2026/470.

Enforcement

Mandatory once transposed

Effective date

Member State transposition deadline 26 July 2027. First wave of in-scope companies covered from 2028.

Covered entities

Large EU and non-EU companies meeting employee and turnover thresholds (revised by 2025 Omnibus and Directive (EU) 2026/470).

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.