Beyond Carrots and Sticks: How the EUs Hybrid Model Outperforms the USs Soft Touchand Builds Stairs for the Developing Countries

This paper comparatively analyzes Human Rights Due Diligence (HRDD) governance models of the European Union and the United States, alongside implementation challenges in developing countries. The EU's hybrid "hard law and soft law" model, anchored in the Corporate Sustainability Due Diligence Directive (CSDDD) and market access leverage, demonstrates greater effectiveness in mitigating supply chain labor rights violations than the US's disclosure-oriented approach, which suffers from enforcement gaps and inadequate remedies. However, developing countries face dual dilemmas: capacity deficits in regulatory infrastructure exacerbate policy conflicts between external standards and local development priorities. To reconcile rights protection with developmental needs, the paper proposes a regulatory adaptation framework for localizing the EU model. The key recommendations include three main points. First, differentiated legislation should exempt SMEs from non-core obligations while prioritizing high-risk industries. Second, adaptive technical reuse must be implemented to address technological gaps. Third, transitional buffers should allow for phased compliance. Sustainable implementation requires shifting global governance from unilateral standard export to collaborative capacity buildingestablishing a "North-South Compliance Fund", technology partnerships, and inclusive consultation mechanisms. This approach builds essential "stairs" for developing economies to achieve rights protection without compromising development.