The EU’s Omnibus I Directive amended CS3D in ways many compliance teams found reassuring. Among the most significant changes: in-depth due diligence is now formally limited to Tier 1 suppliers, the companies a business contracts with directly, unless there is already plausible evidence of adverse impacts further down the chain.
For companies with African supply chains, that reassurance deserves closer examination.
The tier structure matters here. Tier 1 is your direct supplier. Tier 2 is their supplier. Tier 3 goes one level deeper and so on. In African manufacturing, agriculture and extractives, the most significant risks rarely sit at Tier 1. The direct supplier is often commercially organized, with documentation and an audit trail. The risk sits behind them, in the networks and relationships that feed their operations but fall outside the formal procurement relationship.
In practice, this looks like the informal labor broker a Tier 1 supplier uses for seasonal overflow. The artisanal mining cooperative supplying raw materials to a processing facility. The construction sub-contractor brought in by your direct partner, undisclosed and undocumented. None of these sit at Tier 1. All of them carry material exposure under CS3D.
The Omnibus establishes a legal floor at which formal obligations stop, unless triggered by evidence of something worse below. In African markets, that floor is low enough to stand on while significant risk accumulates beneath it.
The further complication is this: the threshold that triggers deeper obligations requires plausible information on adverse impacts at Tier 2 and beyond. That information does not surface through desktop research in African markets. Companies that are not actively investigating their supply chains on the ground will not find it, and will therefore never meet the threshold that requires them to look further.
A compliance program that stops at Tier 1 in an African supply chain has not assessed the risk. It has assessed the part of the risk that was easiest to reach and documented the boundary at which it stopped looking.
Posted by PML Africa on 28 May 2026
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