The EU Forced Labour Regulation (EU) 2024/3015 was published in the Official Journal on 12 December 2024, entered into force on 13 December 2024, and applies from 14 December 2027. On 26 June 2026 the European Commission published its implementation guidelines, launched the Forced Labour Single Portal, and made the forced labour risk database available. For any brand selling into the EU, the framework is now set and the countdown to enforcement has started.
The Regulation prohibits products made with forced labour from being placed on the EU market, made available on it, or exported from it. This article explains what the Regulation requires, who it applies to, how investigations will work, what evidence authorities can demand, and what your brand should do before December 2027. For a deeper analysis of the June 2026 guidelines, see TrusTrace analysis of the FLR guidelines.
The EU Forced Labour Regulation, formally Regulation (EU) 2024/3015, prohibits economic operators from placing products made with forced labour on the EU market, making them available there, or exporting them from it. The prohibition applies to products for which forced labour has been used at any stage of extraction, harvesting, production or manufacturing, anywhere in the supply chain, inside or outside the EU.
The scope is deliberately broad. It covers all products of any type, including their components, with no minimum threshold, so a product is in scope regardless of how small the share made with forced labour is. Only products that have already reached end users are excluded. The Regulation reflects the scale of the problem: it cites an estimated 27.6 million people in situations of forced labour worldwide in 2021.
The Regulation applies to all economic operators that place products on the EU market, make them available there, or export them, regardless of size or turnover. That covers producers, manufacturers, importers, distributors and retailers alike. It is not specific to any industry, material or country of origin, which means textiles, electronics, agriculture, solar and every other sector are in scope, as are goods produced inside the EU.
Products sold online or through other distance sales to EU end users are covered too. Services, including transport and logistics, are excluded.
The Forced Labour Regulation imposes an obligation of result, not an obligation of process. Unlike the Corporate Sustainability Due Diligence Directive (CSDDD), which requires large companies to run a due diligence process, the FLR imposes no due diligence obligation at all. Instead it sets an absolute prohibition: if a product is made with forced labour, it cannot be placed on the EU market or exported. Running good due diligence does not exempt a product from the ban if forced labour is actually present. Due diligence is relevant as evidence you can present to an authority, not as a compliance shield.
The Regulation is already in force, and the most important date for brands is the 14 December 2027 application deadline. The milestones that matter:
Investigations follow a two-phase process led by a competent authority: the European Commission leads when the suspected forced labour occurs outside the EU, and the relevant Member State authority leads when it occurs on its territory. Customs authorities identify affected products at EU borders and cooperate, while the competent authority remains responsible for enforcement.
In the preliminary phase, authorities apply a risk-based approach to decide whether there is a 'substantiated concern' that the ban has been violated, and they take that decision within 30 working days of receiving your information. If a formal investigation opens, you are notified within 3 working days, you are given between 30 and 60 working days to submit requested information, and the authority aims to conclude within 9 months. Prioritisation weighs the scale and severity of the suspected forced labour, the volume of affected products on the EU market, and the share of any suspect component in the final product. State-imposed forced labour is flagged as likely to rank high on scale and severity.
If your products come under assessment, the information authorities can request reads like a traceability specification. Under the guidelines, the product-related evidence includes supply chain maps covering tiers and sub-tiers, chain-of-custody records and raw material traceability data, bills of materials, certificates of origin, supplier lists with facility names and geolocation, purchase orders, invoices and shipping documentation, and the Digital Product Passport identifier where one exists.
Two points carry particular weight. First, the complete lack of, or inability to provide, traceability information where a product may have been mixed with one at high risk of forced labour can weigh negatively in the overall assessment. Missing data is not neutral. Second, non-cooperation, including incomplete or late responses without valid justification, can itself constitute evidence and, combined with other facts, be a sufficient basis to establish a violation. The guidelines are also explicit that social audits conducted where workers cannot speak freely or where access is restricted are not considered credible evidence.
A ban decision prohibits the product, orders its withdrawal from the EU market, and orders its disposal in line with the waste hierarchy. Crucially, the prohibition has general application: it covers any economic operator placing the banned product on the EU market or exporting it, not only the companies investigated, and all decisions are published on the Forced Labour Single Portal. A decision tied to one supplier's products therefore becomes a risk for every brand sourcing from them.
Compliance deadlines start at 30 working days for non-perishable goods and 10 working days for perishable goods. Where only a replaceable part of a product is affected, operators may extract and replace it rather than disposing of the whole product, which is only possible if you know precisely which products contain which components. Penalties are imposed for failing to comply with a ban decision, not for the underlying violation, and Member States set them based on the value of the non-compliant products or a percentage of the operator's annual global turnover.
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The prohibition applies from 14 December 2027. The Regulation itself entered into force on 13 December 2024, and the Commission published its implementation guidelines on 26 June 2026.
No. The Regulation imposes an obligation of result, not a due diligence obligation. However, the Commission's guidelines recognise due diligence, alongside product traceability, as an effective way to demonstrate to authorities that products are not made with forced labour.
All products of any type, including their components, made wholly or partly with forced labour at any stage of extraction, harvesting, production or manufacturing, regardless of sector or country of origin. There is no minimum threshold, and only products that have already reached end users are excluded.
A lead competent authority conducts each investigation: the European Commission when the suspected forced labour occurs outside the EU, and the relevant Member State authority when it occurs on their territory. Customs authorities identify affected products at EU borders and cooperate with the competent authority.
No. A ban decision has general application: it covers any economic operator that places the banned products on the EU market or exports them, not only the companies named in the investigation. All decisions are published on the Forced Labour Single Portal.
TrusTrace helps you build the supply chain traceability foundation the EU Forced Labour Regulation will test: multi-tier supplier mapping, chain-of-custody data, and audit-ready evidence you can retrieve within investigation deadlines instead of scrambling to assemble it. Learn more about TrusTrace Forced Labor Prevention Solution at TrusTrace compliance solution page or Speak with one of our experts.
Disclaimer: This content is for informational purposes only and does not constitute legal advice. Please consult legal professionals for guidance specific to your situation.