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EU Forced Labour Regulation: dates and duties for brands

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Regulation (EU) 2024/3015 bans products made with forced labour from the EU market. It applies from 14 December 2027 to every economic operator that places or makes available products in the EU, or exports them from it. It sets no due diligence duty, but how well you know your supply chain will decide how you fare in an investigation.

Key dates

  1. The Regulation entered into force
  2. Deadline for member states to designate competent authorities
  3. The Commission adopted its guidelines and launched the Forced Labour Single Portal. They were published in the Official Journal on 3 September 2026
  4. Member states must notify the Commission of their penalty rules
  5. The prohibition applies and investigations can begin

Where things stand (15 October 2026)

  • The 14 December 2027 date has not changed. We have found no amendment or delay.
  • The Commission's database of forced labour risk areas and products was still marked "in development" on its own page in early October 2026, although reports differ on whether it has launched. Check the Commission page before relying on either.
  • In August 2026 a law firm counted only eleven member states that had designated their competent authority, against a deadline of December 2025.

Section 01

What it requires

  • It is a ban, not a reporting rule. It covers placing products on the market, making them available and exporting them.
  • It applies to every economic operator, whatever its size, and to every product and sector, including goods made inside the EU.
  • It applies if forced labour was used at any stage of the supply chain, including in only part of a product.
  • It is an obligation of result. Doing due diligence does not exempt a product if forced labour is in it.

Unlike the US UFLPA, which presumes certain goods are tainted until the importer proves otherwise, the EU ban relies on authorities investigating on a risk basis.

Section 02

How enforcement will work

  • National authorities and the Commission investigate on a risk basis, looking at the scale and severity of the suspected forced labour, the volume of products on the EU market and how much of the product it affects.
  • Evidence can come from the risk database, civil society and trade union reports, customs data, satellite imagery and scientific testing, not only from the company.
  • A prohibition decision means the products must be withdrawn from the EU market, and authorities can order disposal.
  • Member states set the penalties. The guidelines give a five-step method based on gravity, duration and circumstances.

Section 03

What the Commission guidelines say

  • Due diligence is not mandatory, but the guidelines are built around the OECD six-step framework and say it helps show your efforts during an investigation.
  • The six steps: build forced labour into your policies and risk management, assess risks, prevent and end them, monitor results, communicate how you address risks, and provide or cooperate in remediation.
  • The guidelines cover privately imposed forced labour, state-imposed forced labour and forced child labour, and list risk indicators such as debt bondage, withheld wages or documents, and restricted movement.
  • Where a risk cannot be fixed in the short term, the guidelines name responsible disengagement as a last step.

Section 04

What to do now

  • Map your supply chain down to raw material level for your highest-risk products, not only your direct suppliers.
  • Identify where your products are exposed by region, sector and material, including any link to state-imposed forced labour.
  • Write down your due diligence against the six OECD steps and keep the evidence: audits, traceability records and corrective action.
  • Add forced labour and remediation clauses to supplier contracts.
  • Watch for the risk database going live and for your national authority being designated.

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Sources

This page is for general guidance and does not constitute legal advice. Requirements depend on your products, entities and markets.

Led by Lavinia Fernandes, a UN/CEFACT UNTP Supply Chain Working Group member.

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