Your Myanmar-based customer or buyer is asking for ESG information. Here is the regulatory and risk environment — and what international buyers need from you.
Myanmar presents one of the most complex ESG risk environments in Asia. Following the February 2021 military coup, Myanmar faces international sanctions, significant human rights concerns, and a deteriorating rule of law environment. Despite this, Myanmar remains a major supplier in the global garment and textile supply chain, as well as in agriculture, timber, and gemstones. International buyers sourcing from Myanmar face heightened due diligence obligations under EU CSDDD, UK Modern Slavery Act, US forced labour laws, and OECD Guidelines for Multinational Enterprises. If you are a Myanmar-based supplier to international buyers, or if you are a buyer assessing Myanmar supply chain risk, this guide sets out the key ESG and compliance considerations.
Key regulations in Myanmar — ESG Supplier Guide
EU CSDDD — Corporate Sustainability Due Diligence Directive
EU companies sourcing from Myanmar — particularly in garments, textiles, footwear, agriculture, and timber — will be required under CSDDD to conduct enhanced human rights and environmental due diligence. Myanmar is classified as a high-risk jurisdiction given the military government's documented human rights violations. EU buyers must identify, prevent, mitigate, and account for adverse human rights impacts in their Myanmar supply chains. Suppliers in Myanmar should expect detailed questionnaires on labour practices, freedom of association, forced labour risks, and environmental management.
UK Modern Slavery Act 2015
UK companies sourcing from Myanmar are required to publish annual Modern Slavery Act transparency statements disclosing steps taken to identify and address modern slavery risks in their supply chains. Myanmar's garment and textile sector, agriculture sector, and fishing industry are identified as high-risk for forced labour, debt bondage, and child labour. UK buyers must conduct enhanced due diligence on Myanmar suppliers and may require suppliers to complete detailed labour rights questionnaires and third-party audits.
US Sanctions and Import Restrictions — OFAC and CBP
The US Office of Foreign Assets Control (OFAC) has imposed sanctions on Myanmar military-linked entities, including the Myanmar Economic Corporation (MEC) and Myanmar Economic Holdings Limited (MEHL). US companies are prohibited from transactions with sanctioned entities. US CBP has issued Withhold Release Orders on specific Myanmar products where forced labour concerns have been identified. US importers sourcing from Myanmar must conduct enhanced supply chain due diligence to identify and avoid sanctioned entities and forced labour risks.
EU Myanmar Sanctions — Arms Embargo and Targeted Measures
The EU has imposed an arms embargo and targeted sanctions on Myanmar military officials and military-linked businesses. EU companies must screen Myanmar business partners and supply chain entities against EU sanctions lists. Companies with Myanmar operations or supply chains should conduct regular sanctions screening and maintain documentation of their due diligence processes.
ILO Forced Labour Convention and OECD Guidelines — Myanmar Application
The International Labour Organization (ILO) has suspended technical assistance to the Myanmar government following the 2021 coup. The ILO continues to document forced labour risks in Myanmar, including military conscription, forced labour in military-controlled enterprises, and labour rights violations in the garment sector. OECD Guidelines for Multinational Enterprises require companies to conduct risk-based due diligence on their Myanmar supply chains and to engage responsibly or consider responsible disengagement where risks cannot be mitigated.
Myanmar Cybersecurity Law & Data Protection — Human Rights Warning
Myanmar's Cybersecurity Law (2021) and the Personal Data Protection Law (under development) provide the legal framework for cybersecurity and data protection. The Ministry of Transport and Communications oversees telecommunications cybersecurity. The political situation following the 2021 military coup has significantly disrupted regulatory development and created severe human rights concerns. International buyers from the EU, UK, or USA face significant due diligence challenges regarding Myanmar suppliers, particularly in the garment and manufacturing sectors. The EU, UK, and USA have imposed targeted sanctions on Myanmar military entities. Suppliers should obtain specialist legal and human rights advice before engaging with Myanmar entities, and implement robust supply chain screening.
What this means for you as a supplier
Myanmar-based suppliers to international buyers face an exceptionally challenging ESG environment. International buyers are required by EU CSDDD, UK Modern Slavery Act, and US sanctions laws to conduct enhanced due diligence on Myanmar supply chains. Buyers may require Myanmar suppliers to complete detailed labour rights questionnaires, undergo third-party social audits, provide evidence of freedom of association and collective bargaining, and demonstrate that their operations are not linked to military-controlled entities. Some international buyers have suspended Myanmar sourcing entirely; others continue with enhanced monitoring. Myanmar suppliers should be prepared to provide comprehensive documentation of their ownership structure, labour practices, and environmental management.
Key dates
February 2021
Military coup — EU, US, and UK sanctions imposed on military-linked entities; heightened due diligence obligations for international buyers
2021 (ongoing)
US CBP Withhold Release Orders — specific Myanmar products subject to import restrictions on forced labour grounds
July 2029
CSDDD Phase 1 — largest EU companies must conduct enhanced supply chain due diligence for high-risk jurisdictions including Myanmar
High-risk jurisdiction: enhanced due diligence required
Myanmar is classified as a high-risk jurisdiction for human rights due diligence by the EU, UK, US, and major ESG rating agencies. The February 2021 military coup has resulted in documented human rights violations including forced labour, arbitrary detention, and violence against workers and civil society. International buyers are legally required under EU CSDDD, UK Modern Slavery Act, and US sanctions laws to conduct enhanced due diligence on Myanmar supply chains. Buyers must identify whether their Myanmar suppliers have any ownership links to Myanmar Economic Corporation (MEC), Myanmar Economic Holdings Limited (MEHL), or other military-controlled entities — any such links trigger US and EU sanctions compliance obligations. Myanmar suppliers should proactively prepare ownership structure documentation, labour practice evidence, and third-party audit reports to facilitate buyer due diligence.
Garment sector: the primary international supply chain exposure
Myanmar's garment and textile sector employs approximately 700,000 workers and is the country's largest export industry. Major international fashion brands including H&M, Primark, and Inditex have sourced from Myanmar. Following the 2021 coup, many brands suspended or significantly reduced Myanmar sourcing. Those that continue sourcing apply enhanced monitoring requirements including regular social audits, worker grievance mechanism verification, and freedom of association assessments. Myanmar garment suppliers should be prepared to evidence: compliance with Myanmar Labour Law (to the extent it is enforced), freedom of association and collective bargaining rights, absence of child labour, wage payment practices, and workplace health and safety standards.
Responsible disengagement: when to exit Myanmar supply chains
OECD Guidelines for Multinational Enterprises and the UN Guiding Principles on Business and Human Rights provide guidance on responsible disengagement from high-risk supply chains. Where a company cannot prevent or mitigate adverse human rights impacts in its Myanmar supply chain — for example, where a supplier has links to military-controlled entities, or where labour rights violations cannot be remediated — responsible disengagement may be the appropriate response. However, abrupt disengagement can harm workers who depend on international supply chain employment. Companies considering Myanmar disengagement should consult the OECD's Responsible Business Conduct guidance and engage with affected workers and civil society organisations before making sourcing decisions.
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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