Your Dutch customer is not legally required to ask you this. They are asking anyway.
The Wet Zorgplicht Kinderarbeid (Child Labour Duty of Care Act) passed the Dutch parliament in May 2019. It has not yet entered into force. There is no active penalty for Dutch buyers who do not conduct child labour due diligence today. And yet Philips, Unilever, IKEA Netherlands, Heineken, Shell, and others are already sending structured questionnaires to their suppliers. They are doing it because they decided to — ahead of the law, ahead of enforcement, ahead of any external pressure that would require it. That is a different kind of questionnaire to the one a German buyer sends under LkSG. The Dutch buyer is not protecting themselves from a fine. They are making a choice about what kind of supply chain they want.
Key regulations in Netherlands — Wet Zorgplicht Kinderarbeid Supplier Guide
Wet Zorgplicht Kinderarbeid — Dutch Child Labour Duty of Care Act
The Wet Zorgplicht Kinderarbeid requires companies selling goods or services to Dutch end-users to investigate whether child labour occurs in their supply chain. If there is a reasonable suspicion of child labour, the company must draw up and implement an action plan. Companies must submit a declaration to the Netherlands Authority for Consumers & Markets (ACM) confirming they have carried out due diligence. The law applies to all companies — Dutch and foreign — that sell to Dutch consumers or businesses, regardless of size. There is no SME exemption. Penalties for non-compliance include administrative fines of up to €870,000 and criminal prosecution for repeated violations.
ACM — Netherlands Authority for Consumers & Markets
The ACM (Autoriteit Consument & Markt) is designated as the supervisory authority for the Wet Zorgplicht Kinderarbeid. It already enforces consumer protection and market competition law in the Netherlands. When the child labour act comes into force, the ACM will receive company declarations, investigate complaints, and issue fines. The ACM has a track record of active enforcement in other areas — companies should not assume the child labour act will be lightly enforced.
CSDDD — EU Corporate Sustainability Due Diligence Directive
The Netherlands' child labour act is expected to be superseded or absorbed by the EU CSDDD, which covers human rights and environmental due diligence across the full supply chain — not just child labour. Dutch buyers are already preparing for CSDDD compliance, which means their supplier questionnaires are expanding beyond child labour to cover forced labour, living wages, environmental impacts, and governance. Suppliers who respond well to the current child labour questionnaire will be ahead of the curve when CSDDD questionnaires arrive.
Dutch GDPR (AVG) & NCSC Cyber Obligations
The Netherlands implements GDPR (known as AVG — Algemene Verordening Gegevensbescherming) with 72-hour breach notification to the Autoriteit Persoonsgegevens (AP). The AP is an active enforcer: fines have included EUR 525,000 (Booking.com, 2020) for delayed breach notification. NIS2 implementation through the Dutch Cyberbeveiligingswet requires essential and important entities to report significant incidents to the NCSC (Nationaal Cyber Security Centrum) within 24 hours (initial notification) and 72 hours (detailed report). The NCSC coordinates national cyber incident response and issues binding guidance. The Dutch Digital Infrastructure Act (Wet beveiliging netwerk- en informatiesystemen, Wbni) is being updated for NIS2. Suppliers processing Dutch customer data must align incident response to the AP 72-hour GDPR window and NCSC NIS2 reporting requirements.
What this means for you as a supplier
You are not directly regulated by the Wet Zorgplicht Kinderarbeid. But your Dutch buyer is preparing for it — and for the CSDDD that follows. The law requires them to investigate child labour in their supply chain and submit a declaration to the ACM. A non-response from you means they cannot complete that declaration. Dutch buyers are also under pressure from their own customers, investors, and NGOs to demonstrate clean supply chains now, before the law is formally active. Your questionnaire response is part of their compliance record — and your absence from it is a gap they will notice.
Key dates
May 2019
Wet Zorgplicht Kinderarbeid passes Dutch parliament — law exists but implementation date not yet set
2022–present
Dutch buyers applying child labour due diligence principles voluntarily — supplier questionnaires already in circulation
2024
Netherlands government confirms alignment with CSDDD — implementation timing linked to EU transposition
July 2029
CSDDD Phase 1 — EU-wide supply chain due diligence for largest companies; Dutch buyers in scope
2027–2029
Expected window for Wet Zorgplicht Kinderarbeid to enter into force alongside CSDDD transposition
2029
CSDDD Phase 3 — companies with ≥1,000 employees; all Dutch buyers in scope
No enforcement yet — but the questionnaires are real
The Wet Zorgplicht Kinderarbeid has been law since 2019 but has no implementation date. The Dutch government is waiting for the EU CSDDD to be transposed before activating it. That means your Dutch buyer faces no legal penalty today for not assessing their supply chain. They are doing it anyway. This matters because it tells you the questionnaire is not a box-ticking exercise driven by a compliance deadline. It reflects a deliberate decision by the buyer about their supply chain standards. When the law does come into force — expected 2027–2029 — it applies immediately, with no transition period and no SME exemption.
Which companies are required to comply
The Wet Zorgplicht Kinderarbeid applies to any company — Dutch or foreign — that sells goods or services to Dutch end-users or businesses. There is no revenue threshold and no SME exemption. If you sell into the Dutch market, the law will apply to you. The key trigger is selling to Dutch buyers, not your own size or location.
- • Any company selling goods or services to Dutch buyers
- • Dutch companies and foreign companies alike
- • No size threshold — SMEs are included
- • All sectors where child labour risk exists
- • Your buyer needs to submit an ACM declaration
- • Their declaration must cover their supply chain
- • You are part of their supply chain
- • Their CSDDD preparation is already underway
What your Dutch buyer must do
When the law enters into force, Dutch buyers must complete three steps. They are already working through these steps voluntarily.
What your questionnaire will cover
Dutch buyer questionnaires based on the Wet Zorgplicht Kinderarbeid typically cover six areas. As CSDDD preparation accelerates, many Dutch buyers are already expanding their questionnaires beyond child labour to cover the full human rights and environmental agenda.
Penalties when the law enters into force
The Wet Zorgplicht Kinderarbeid includes significant penalties. These apply to your buyer — but your buyer's ability to comply depends on your cooperation.
| Violation | Penalty | Enforcer |
|---|---|---|
| Failure to submit ACM declaration | Administrative fine up to €870,000 | ACM |
| Failure to carry out due diligence | Administrative fine up to €870,000 | ACM |
| Repeated non-compliance | Criminal prosecution of the company | Public Prosecutor |
| Repeated non-compliance by director | Criminal prosecution of the individual | Public Prosecutor |
How this compares to Germany's LkSG
| Feature | Netherlands (WZK) | Germany (LkSG) |
|---|---|---|
| Status | Passed — not yet in force | In force since January 2023 |
| Scope | Child labour only | Human rights & environment (broader) |
| SME exemption | None — all companies in scope | Yes — 1,000+ employees |
| Threshold to trigger | Selling to Dutch buyers | Buyer has 1,000+ employees |
| Enforcement body | ACM | BAFA |
| Max fine | €870,000 | €8 million / 2% of global turnover |
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.
Received a WZK questionnaire from your buyer?
ESG Stress Free guides Dutch suppliers through the Wet Zorgplicht Kinderarbeid and CSRD supply chain requirements.