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The EU Forced Labour Regulation bans products made with forced labor from the EU market. From 14 December 2027, companies cannot place or make such products available in the EU, or export them. It covers products made inside and outside the EU, and companies of all sizes.
This guide explains the EU Forced Labour Regulation’s scope, the key dates, how investigations work, what happens to banned products, and what brands should prepare now.
What the EU Forced Labour Regulation Covers
The law is Regulation (EU) 2024/3015 of 27 November 2024. Under Article 3, economic operators shall not place or make available on the Union market products made with forced labor. Nor shall they export them.
- Forced labor follows the definition in Article 2 of ILO Convention No 29. It includes forced child labour.
- A product made with forced labor is one where forced labor was used in whole or in part. That can be at any stage of extraction, harvest, production or manufacture.
- A product is anything that can be valued in money and traded.
- An economic operator is anyone who places or makes products available on the EU market, or exports them.
- Distance sales are covered by Article 4.
The EU Forced Labour Regulation does not create new due diligence obligations beyond existing EU or national law (Article 1(3)).
Under the EU Forced Labour Regulation, the test is whether the product was made with forced labor.
EU Forced Labour Regulation Key Dates
| Date | Milestone |
|---|---|
| 27 November 2024 | Date of the regulation |
| 13 December 2024 | Entry into force |
| 14 June 2026 | Deadline for the risk database and guidelines (Articles 8 and 11) |
| 30 June 2026 | Commission launched a preparedness package and the Forced Labour Single Portal |
| 14 December 2026 | Member States notify their penalty rules to the Commission (Article 37) |
| 14 December 2027 | The ban applies and the Single Information Submission Point opens |
How Investigations Work Under the EU Forced Labour Regulation
Enforcement is risk based. Authorities weigh criteria such as the scale and severity of the suspected forced labor and the volume of products on the EU market (Article 14).
The location of the suspected forced labor determines which authority leads the investigation. A national competent authority leads when the suspected forced labor is in its territory. The European Commission leads when it is outside the EU (Article 15).
Preliminary phase
The authority can ask companies for information. Companies have 30 working days to reply. The authority then has 30 working days to conclude this phase (Article 17).
Investigation
If it opens an investigation, the authority informs the companies within 3 working days. They get at least 30 and no more than 60 working days to submit information (Article 18).
Inspections
Field inspections happen only in exceptional situations. Outside the EU, the Commission needs the company’s consent and no objection from the government concerned (Article 19).
Decision
The authority should aim to decide within 9 months of opening the investigation (Article 20).
What Happens if Forced Labor Is Found
A decision under Article 20 includes:
- A ban on placing the products on the EU market and on exporting them.
- An order to withdraw products already on the market.
- An order to dispose of them.
Companies get at least 30 working days to comply, or 10 working days for perishable goods, animals and plants (Article 22). Products are recycled or, if that is not possible, rendered inoperable. Perishable products are donated for charitable or public interest purposes where possible (Article 25).
Customs authorities receive these decisions and use them in risk-based controls (Article 26). Member States set penalties for failing to comply. They must be effective, proportionate and dissuasive (Article 37).
Database and Guidelines
The European Commission has published guidelines. Its risk database is still in development. The database is meant to give indicative, non-exhaustive information on forced labor risks by product and geographical area. The guidelines cover due diligence, risk indicators and how to submit information, among other topics. An SME preparedness checklist is also available.
How to Prepare for the EU Forced Labour Regulation
- Map your supply chain. List the component and raw material suppliers behind each product, beyond the assembly factory. Check them against the Commission’s risk database once it goes live.
- Keep records ready to send. Authorities give 30 working days to answer requests for information. Hold supplier lists, audit reports, purchase orders and traceability data in one place.
- Write forced labor terms into supplier contracts. Include audit access and a duty to disclose sub-suppliers.
- Audit high-risk tiers. An audit records conditions on the days it covers. Treat it as one input, not proof.
- Plan for remediation. Decide in advance how you would respond if a supplier is found to use forced labor.
Managing forced labor risk forms part of wider ESG work. Our guide on ESG for manufacturers explains where to start. Our overseas manufacturing tips cover the wider basics of working with factories abroad.
Final Thoughts
The EU Forced Labour Regulation applies from 14 December 2027, and the guidance is already out. Brands selling into the EU should map suppliers, organize records and update contract terms now. Response deadlines are counted in working days, so records need to be ready before any request arrives.
Our product sourcing service runs due diligence checks on factories, including company registration and certifications, before you commit.
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