The European due diligence directive that your buyers keep mentioning does not bind you. Since February 2026 it binds a great deal fewer of them, too. The questionnaires have not stopped arriving, and they are not going to.
That gap, between what the law now formally requires and what the market has settled into asking for, is where a supplier either wins accounts or slowly loses them. It is worth being precise about both halves.
What the directive says after the rewrite
The Corporate Sustainability Due Diligence Directive as amended is Directive (EU) 2026/470. The Council approved it on 24 February 2026, it was published in the Official Journal on 26 February 2026, and it entered into force on 18 March 2026. Member states have until 26 July 2028 to transpose it, and it applies from 26 July 2029.
Those last two dates are worth holding on to, because a directive in force is not a directive in operation. Nothing in it obliges anybody to do anything until 2029, and the national laws that will actually carry the obligations do not yet exist in final form in any member state.
The Omnibus I package raised the thresholds sharply. An EU company is now caught only if it has more than 5,000 employees and more than 1.5 billion euros in worldwide net turnover, both conditions together. A non-EU company is caught at more than 1.5 billion euros of EU turnover. The previous figures were 1,000 employees and 450 million euros.
That is not a trim. Moving from 1,000 employees to 5,000, and from 450 million euros to 1.5 billion, removes a whole tier of buyer from scope: the substantial European stone importer, the regional distributor, the fabricator group with a few hundred staff. Most companies buying dimension stone or chromite out of Pakistan will never be caught, and a fair number of those sending out compliance questionnaires today are not caught either.
Why the questionnaires keep coming anyway
Two reasons, and only one of them is legal.
The legal reason is that where a company is in scope, its due diligence runs through its chain of activities to its business partners. The obligation is the buyer's, but it cannot be discharged inside the buyer's own four walls. It reaches back to the quarry, and it reaches back through whoever sits between you and the quarry. The Omnibus amendments did put a qualifier on how far that reach can extend in practice: information requests to partners are to be necessary, targeted, reasonable and proportionate. That is a real constraint on volume and intrusiveness, and a supplier facing a thirty page questionnaire from a buyer with no obvious risk exposure is entitled to say so.
The commercial reason is larger. The audit culture the original directive created did not recede when the thresholds moved. Procurement teams wrote supplier codes, banks wrote covenants, and large customers wrote flow down clauses, all calibrated to the old figures. None of that paperwork rescinds itself because a threshold changed in Brussels. A buyer well below 5,000 employees will still ask, because its own customer asks it, and because the clause is already in the template.
So the practical position for a supplier in Pakistan is unusual. Fewer counterparties carry the legal duty than at any point since the directive was first agreed, and the number of questionnaires has not fallen.
Two claims we are not repeating
There are two assertions circulating in commentary on the amended directive that we have not been able to confirm against the instrument itself.
The first is that harmonised civil liability was removed. The second is that a hard numeric cap now exists on the volume of information that can be requested from a small or medium sized supplier. Both are stated confidently in places. We could verify neither, and we are not going to reprint them as fact simply because they would be convenient for our clients if true.
This is general commentary on published instruments rather than legal advice. If either of those points is load bearing in a contract you are being asked to sign, that is a question for counsel reading the transposing national law, which does not exist yet, rather than for anybody reading the directive from the outside.
The standard that actually governs the conversation
Long before any of the European legislation, the reference framework for minerals was the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The third edition remains the standard, and it is what a serious buyer's compliance function is working from when it drafts a questionnaire.
Its structure is a five step framework with an Annex II risk list. Working through those five steps is the closest thing to a universal answer available to a supplier, because it is what the European rules were built on top of, what most bank and buyer codes cite directly, and what does not move when a threshold in an omnibus package moves. A chromite producer who can walk a buyer through it is answering a question that will still be the same question in 2029.
Certification for stone, honestly described
For natural stone specifically, European buyers work with two schemes: XertifiX and Fair Stone. Both cover the ILO core conventions, child labour, health and safety, wages and legality, and both use unannounced third party audits at the quarry and at the factory.
The unannounced element is the part sellers underestimate. It means readiness is a standing condition of the site rather than a project that runs for three weeks before an inspection. A quarry that can pass on any given Tuesday is a different operation from one that can pass on a scheduled date.
One caveat that we would rather state than let a client discover, and it applies to both schemes rather than to either alone. XertifiX and Fair Stone each publicly describe operations in India, China and Vietnam. Neither publishes coverage in Pakistan that we have been able to verify. Anyone telling a producer outside those three countries that either certification is straightforwardly available to them is making a claim we cannot substantiate. The first step is to ask the scheme directly whether it audits in your region, before anyone budgets for a certificate or writes one into a contract.
Quarrying is not in the deforestation regulation
A related question arrives constantly, so it is worth closing it out. The EU Deforestation Regulation applies from 30 December 2026 for large and medium operators and from 30 June 2027 for micro and small operators, having been delayed twice.
Its scope is seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood, together with products derived from them. Mining and quarrying land use is not covered. A delegated act in July 2026 adjusted Annex I and added no minerals to it. A granite block does not require a due diligence statement under that regulation, and a chromite parcel does not either.
The instructive detail is that the July 2026 adjustment was an opportunity to add minerals and did not. Land use regulation is the most obvious future route into quarrying, and the drafters have now passed on it once.
What to build while nobody is obliging you to
The asymmetry running through all of the above is that the legal duty sits with the buyer while the evidence sits with the supplier. That does not change with thresholds, and it does not change with dates.
The commercial consequence is specific. A due diligence questionnaire arrives at the worst moment for your negotiating position, usually mid negotiation or shortly before a first order, and the supplier who answers it in a week takes business from the supplier who takes a quarter. The file that answers it, being a set of facts about your own operation, is built once and reused for every buyer who asks. That is rare in this trade, where almost every cost is per shipment.