LkSG: what Germany’s supply chain law requires of Brazilian suppliers
How Germany’s Supply Chain Due Diligence Act reaches Brazilian suppliers who have no direct relationship with German law, and what buyers end up asking for.
What the LkSG is
The LkSG (Lieferkettensorgfaltspflichtengesetz, the Supply Chain Due Diligence Act) makes German companies above a size threshold responsible for identifying, preventing and mitigating human rights and environmental violations in their supply chain — not only in their own operations, but at their suppliers, direct and in defined circumstances indirect.
How it reaches a supplier who has never heard of it
A Brazilian supplier is not directly regulated by the LkSG. The law is German and applies to German companies. But the effect arrives indirectly and concretely: the German buyer, to satisfy its own legal obligation, has to demonstrate due diligence over its chain — which means requesting evidence and, in some cases, requiring by contract that suppliers cooperate with monitoring.
This is why a Brazilian exporter can suddenly start receiving detailed due diligence questionnaires — on forced labour, working conditions and environmental impact — from German buyers who never asked before. The German company is meeting its own obligation, and the Brazilian supplier is part of the chain that has to be documented.
What buyers actually ask for
In practice the points raised in LkSG-driven questionnaires overlap almost exactly with what other requirements already check: absence of forced or slavery-like labour (which Brazil’s Lista Suja already signals), absence of corruption or irregularity sanctions (CEIS/CNEP), and, where relevant to the product, environmental origin evidence (CAR, deforestation, embargoes) — the same base set underpinning the EUDR.
That overlap is the useful part. A supplier monitoring process built for one of these requirements answers most of the others with the same evidence.
What good preparation looks like
The best preparation for an LkSG questionnaire is not waiting for it to arrive before gathering data. It is having the same evidence other international requirements already ask for — forced labour register, federal sanctions, and where applicable environmental data — continuously maintained and ready to export as a report the moment the question arrives.