The Legal Position of Animals in Global Supply Chains: A Comparative Analysis of Corporate Regulation Frameworks and Their Limitations

Every year, billions of animals worldwide are raised, exploited and slaughtered for corporate purposes, particularly within the food production and garment manufacturing sectors. These industries represent the quantitatively most significant areas of animal use, raising serious concerns regarding animal rights violations, while also generating significant environmental and social impacts. Such criticalities are exacerbated by the widespread outsourcing of production to foreign business partners and suppliers, with the creation of complex, global supply chains characterised by opacity and fragmented accountability. Against this background, this research seeks to verify whether specific duties and liabilities towards animals are imposed on companies involved in supply chain stages, also assessing whether animal protection may be derived from environmental and human rights laws, in light of the strong interconnected nature of these concerns. The presentation adopts a comparative approach to analyse international soft law instruments alongside national and supranational legal frameworks related to the regulation of supply chain relationships and the management of non-financial adverse impacts, thus assessing their role in shaping corporate responsibilities towards animals exploited in such contexts. The analysis shows that international soft law instruments, including the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, address animal welfare only marginally, primarily by requiring compliance with the World Organisation for Animal Health’s Terrestrial Animal Health Code. National laws – either providing transparency requirements (e.g. the California Transparency in Supply Chains Act, the UK and Australian Modern Slavery Acts) or due diligence obligations (e.g. the French Loi de Vigilance and the German Lieferkettensorgfaltspflichtengesetz) - systematically overlook animals’ position, focusing exclusively on environmental and human rights concerns. By contrast, the EU Corporate Sustainability Due Diligence Directive - which requires companies within its scope to identify, prevent, and mitigate non-financial adverse impacts arising from their own activities and those of their suppliers - emerges as a more advanced legal framework in this field. Although formally centred on environmental and human rights protection, the Directive explicitly embraces the “One Health” approach and recognises animal well-being among its objectives. More specifically, it refers to a series of international conventions, the violation of which would constitute a “negative impact” that companies are required to address through due diligence procedures. Among these, the Directive expressly mentions the Convention on Biological Diversity and the Convention on International Trade in Endangered Species of Wild Fauna and Flora. On this basis, the research, on the one hand, examines the extent to which the Directive may integrate animal welfare into corporate non-financial due diligence obligations; on the other hand, it argues that this approach remains inadequate to ensure effective protection for animals, as it continues to prioritize ecosystem preservation and human production. In conclusion, through a comparative legal analysis, the research provides an overview of the legal positioning of animals within global supply chains, highlighting both the divergences among legal systems and their shared shortcomings in defining corporate duties and liability regimes concerning animals.