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28 Nov 2025

Legal Opinion on the Responsibility of Amazon with Respect to Human Rights due Diligence Over Third-Party Supply Chains

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Legal Opinion on the Responsibility of Amazon with Respect to Human Rights due Diligence Over Third-Party Supply Chains
As millions of products are set to be purchased on Amazon this Black Friday, the company’s responsibility to ensure that these sales are not built on labour exploitation has never been more critical.
Last year alone, independent sellers on Amazon’s platform sold over 750 million products during the Black Friday–Cyber Monday period, a record-breaking figure that illustrates just how powerful Amazon’s marketplace model has become. But with this scale comes responsibility. In a new legal opinion, Ana Santos Duarte, Business & Human Rights Legal Adviser at GRC, examines Amazon’s obligations under international business and human rights standards and emerging EU legislation.
The analysis draws on Labour Behind the Label’s report ‘Unboxing Marketplace Fashion: Worker rights in the supply chains behind online fashion consumption, which documented indicators of forced labour, wage theft and other abuses at three Pakistani garment factories, she highlights that Amazon’s relationship with third-party (3P) sellers.
The opinion highlights that Amazon’s relationship with its 3P sellers constitutes a business relationship under the UN Guiding Principles on Business and Human Rights (UNGPs) and the OECD Guidelines, meaning its human rights due diligence efforts are expected to also cover these sellers and their supply chains, rather than relying on reactive or after-the-fact measures. It also warns that as the Corporate Sustainability Due Diligence Directive (CSDDD) and EU Forced Labour Regulation (EUFLR) come into effect, the stakes are even higher.
Failure to address human rights risks in its marketplace supply chains could result not only in reputational harm, but also in legal consequences, including the withdrawal of products linked to forced labour from the EU market. This assessment underscores an urgent need for Amazon to strengthen its human rights due diligence processes and ensure that its marketplace model does not contribute to systemic labour exploitation.
Read the full legal opinion here.