Introduction

In the garment clusters of Delhi and Tiruppur, a lot of the work on clothes sold in European shops happens at home. Women cut threads, sew on buttons and add embroidery, paid per finished piece, in the same room where they cook and sleep. They sit several subcontracts away from the brand on the label, and many of them never learn its name. This is routine: in one survey of 340 garment factories in Delhi and Bengaluru, 58% passed work on to homeworkers (von Broembsen, 2022).

The EU's Corporate Sustainability Due Diligence Directive  (CSDDD) was meant to improve conditions for affected workers (European Union, 2024). In February 2026 the European Parliament passed an amended version of the CSDDD. This article argues that the amended directive tends to stop looking where a company's own contracts end, which leaves homeworkers out. Their position also exposes a second kind of labour the directive ignores: the unpaid household work that keeps every garment worker able to work.

 Why garment work ends up in homes

Two kinds of work matter for the CSDDD. The first is homework: paid, piece-rate production that factories and contractors hand out to workers in their homes. On paper the directive covers it as part of a company's chain of activities; in practice its tools rarely reach it. The second is reproductive labour: the unpaid cooking and caring that keeps workers fed and able to return to work each day.

Homework grows out of the buying strategies of global brands. Short lead times and the threat of moving orders to other suppliers, often in other countries, squeeze prices and make volumes hard to predict. Early in the COVID-19 pandemic, many European and US brands cancelled orders or refused to pay for goods already in production (Anner, 2020). Indian export firms, which take orders from the brands, pass this pressure down to smaller workshops. Almost 90% of India's garment workers work in small and medium enterprises, and these firms hand work out to homes to meet rush orders without taking on extra workers, space or machines (Mezzadri, 2016; von Broembsen, 2022).

As feminist political economists have long argued, paid work depends on unpaid reproductive work. Women do most of it, and employers benefit from a workforce whose daily upkeep they do not pay for in full (Dalla Costa and James, 1972; Federici, 2004; Bhattacharya, 2017). Mies (1982) traced this among home-based lace makers in Narsapur, whose work was treated as a housewife's spare-time activity and paid accordingly. The same subsidy lets employers of factory workers and homeworkers alike pay wages below what it costs to keep a household going.

Homework is where this dependency becomes particularly visible. A factory worker does paid work and housework in separate places and at separate times. A homeworker does both in the same room. She finishes garments between childcare and cooking, in a space that is also kitchen and bedroom, at hours that fall outside any normal working day (Mezzadri, 2017). The employer pays only for finished pieces; unpaid reproductive work covers the rest. Before the COVID-19 pandemic, homeworkers earned between a half and a third of the minimum wage and paid for their own workspace and equipment out of those earnings (von Broembsen, 2022). Women make up around 80% of the textile, garment and footwear workforce, and cluster in piece-rate work and homework (ILO, cited in von Broembsen, 2022).

As of now, legal protection for homeworkers is thin. Only 13 countries have ratified the ILO's Home Work Convention (No. 177), and India is not among them (HomeNet International, 2023). Better auditing is also unlikely to close the gap. Suppliers often keep one factory that meets brand codes while sending work to unaudited sites, so the cost of better conditions for audited workers tends to land on those outside the audit (von Broembsen, 2022).

What the CSDDD asks of companies, before and after 2026

Corporate sustainability due diligence means a company checks its own operations and supply chain for harm to people and the environment, such as forced labour or pollution, and acts to prevent or stop it. The CSDDD (Directive (EU) 2024/1760) turned this from voluntary guidance into a legal duty for large companies operating in EU member states. As a directive, it binds member states, which translate it into national law and enforce it. It covers a company's "chain of activities": the businesses that design, source, make and supply its products, including indirect suppliers several steps along the supply chain, plus some downstream transport and storage. In its original form, companies had to map these operations to find where harm was most likely and most severe. Member states also had to let victims, meaning the workers and communities harmed, sue a company for damages if it failed to prevent harm it should have prevented.

The amending act, Directive (EU) 2026/470, part of the Commission's "Omnibus I" simplification package (European Commission, 2025), was adopted on 24 February 2026 and, after the Council's final sign-off, entered into force on 18 March 2026 (Council of the European Union, 2026). Companies must comply from July 2029. The act narrows the CSDDD in three ways. First, it applies only to EU companies with more than 5,000 employees and more than €1.5 billion in worldwide turnover, and to non-EU companies with more than €1.5 billion in turnover inside the EU (European Union, 2026, Art. 4(5)). These thresholds apply to the buyers that carry the duty, not to their suppliers. Second, it deletes the EU-wide civil liability rule, so each member state now decides whether and how victims can sue.

Third, and most important for homeworkers, it changes how companies look for harm. Companies no longer have to map their supply chains. Instead, they carry out a "scoping exercise, based solely on reasonably available information" (Art. 8(2), as amended). The directive does not define reasonably available information. The recitals give companies "flexibility" in judging it, and state that relying on it "will as a general rule preclude requesting information from business partners" (European Union, 2026, Recital 39). Where harms look equally likely or equally severe in several places, the company may deal with its direct suppliers first (Art. 8(2a)(c)).

A company may request information only where it is "necessary" (Art. 8(2a)(a)). The directive ties necessity to the areas the scoping has already flagged: companies "should not be required to request any information from business partners where no likely and severe risks were identified" (Recital 40). From a partner with fewer than 5,000 employees, the company may request information only where it "cannot reasonably be obtained by other means", and any request should be "targeted, reasonable and proportionate" (Art. 8(2a)(a); Recital 41).

The directive, then, does not forbid companies to send due diligence requests to their suppliers. It makes a request the exception, and most suppliers in Indian garment production have far fewer than 5,000 employees. This creates a loop. A company may ask about homework once its scoping flags homework as a likely and severe risk, but the scoping runs on what the company already knows, and companies rarely know about homework. A brand knows a lot about its direct supplier, because the contract produces addresses, audit reports and correspondence. It has no comparable record of a homeworker several subcontracts away, because that layer runs on informal arrangements, often without written contracts (Mezzadri, 2016). In this way, the directive discourages the very inquiries that would bring homework to light. On paper the rules apply to every tier; in practice they point companies to their direct suppliers.

Would the original 2024 directive have done better? Partly. It required companies to map indirect suppliers too, and the EU-wide liability rule gave them a reason to do it carefully. Homework would still have been hard to find, but the original directive at least expected companies to go looking. The amended CSDDD steers them away from searching deeper in their supply chains.

The objection

A defender of the amendments might say the directive already offers a way in. If a company receives credible evidence of harm among home-based subcontractors, through worker complaints or NGO reports, that evidence becomes reasonably available, and the company has to act on it, whatever the tier. On this view, better documentation will close the gap between the tiers the directive covers on paper and the ones companies actually see.

This reading underestimates how the directive interacts with informal work. For information to count as reasonably available, someone has to identify the worker and the harm first. Output passes through several layers of subcontracting before it reaches an exporter, and factories often hide brand names from the workers who make the goods (von Broembsen, 2022). A homeworker who does not know which brand she sews for cannot complain to it. The burden of producing evidence is the highest where records are scarcest, and the one actor able to demand those records, the buyer, is discouraged from asking.

Suggested amendments to the CSDDD

Legal recognition of homework and subcontracting. When member states transpose the amended directive, and when the Commission reviews it (due by 2031), information about home-based and informal subcontracting should count as reasonably available by definition. To make this workable, brands would contractually require suppliers at every tier to keep a register of the homeworkers they use, recording names, contact details, quantities produced and pay, and to give every worker a written contract that names the brand she is producing for. Von Broembsen (2022), writing for WIEGO (Women in Informal Employment: Globalizing and Organizing), proposes both, and 14 homeworker organisations have put their own platform of demands to the Commission. The OECD's due diligence guidance for the garment sector already points in this direction (OECD, 2017). Since registers mean asking smaller suppliers for information, the directive would need an explicit exception for them from the limit in Article 8(2a).

Translating piece rates into living wages. TPiece rates should be tied to a living wage benchmark based on what it costs to keep a household going in that region (Asia Floor Wage Alliance, 2023). Minimum wages are set for hourly or monthly work and translate poorly to someone paid by the piece, whose paid hours are broken up by unpaid housework and whose earnings have to cover her household's upkeep.

Neither proposal asks the directive to regulate households. The registers simply record an existing business relationship, as a tier-one contract already does. The wage floor shifts onto buyers some of the cost of reproduction that homeworkers' households now carry. Where the directive currently stops is a policy choice, and the EU can change it.

Conclusion

The amended CSDDD's blind spot comes from its scoping standard, which leaves it to companies to judge what information is reasonably available. More auditing inside the mapped chain will not remove it, and may push more production into homes.

The problem is set to grow. India and the EU concluded negotiations on a free trade agreement on 27 January 2026. Once it enters into force, Indian textiles and clothing will enter the EU duty-free (Press Information Bureau, 2026), on top of apparel exports that already reached a record USD 4.66 billion in 2025–26 (Apparel Resources, 2026). More trade means more European orders passing through Indian subcontracting networks, and more homework the amended CSDDD is unlikely to see.

Mapping homework would bring the paid tier of the supply chain into the CSDDD's view. It would also make the unpaid reproductive labour behind it harder to ignore, since homework is where that subsidy is easiest to see. Addressing the subsidy will take more than better mapping, but making it visible is where that work can start.

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About the Author

Shloka Murarka is an EPOG+ Erasmus Mundus scholarship holder, currently pursuing a postgraduate degree in International Economics, with her first year based at the Berlin School of Economics and Law (HWR). She holds a BSc in Economics from SOAS University of London, where she served as President of Rethinking Economics SOAS and is an organiser with the Development Working Group of the Young Scholars Initiative (YSI). Her academic and activist interests focus on the feminist political economy of labour.

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References

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