From December 2027, an EU-wide ban on products manufactured using forced labour will come into force. The basis for this is Regulation (EU) 2024/3015, which was published in the EU Official Journal at the end of 2024. This Forced Labour Regulation prohibits trade in goods from forced labour in the European Union from 14 December 2027. The ban covers both the placing and making available of such products on the EU internal market and their export from the EU. In the following article, we explain what the regulation regulates, who it affects and which measures companies should take now.
Background: Why a ban on products from forced labour?
It is estimated that over 27 million people worldwide are affected by forced labour, in many sectors, particularly in textile manufacturing, agriculture and mining, and on all continents. Faced with this reality, the EU has decided to act: Back in September 2022, the EU Commission proposed a ban on products manufactured using forced labour. Following negotiations between the European Parliament and the Council, the regulation was formally adopted at the end of 2024. It will enter into force on the day after publication and will apply after a transitional period of three years, i.e. from 14 December 2027. This long lead time is intended to give companies the opportunity to make the necessary changes to their supply chains.
What does the Forced Labour Regulation regulate?
Regulation (EU) 2024/3015 creates a comprehensive legal framework to take action against products from forced labour. At its core is a general ban on placing, making available on the market or exporting such goods in the EU. All products of any kind – including all components – are subject to the ban, regardless of the country of origin or place of production. If a product is identified as having been produced using forced labour, its distribution must be stopped immediately. Affected goods must be withdrawn from the market and may not be exported from the EU. In this way, the EU wants to ensure that no more products produced by forced labour reach the European internal market or are resold from there.
Products with an increased risk of forced labour in the supply chain include agricultural products such as cocoa, coffee, tea, sugar cane, palm oil, cotton, rice, fish and seafood. In the textile sector, it is clothing, shoes and carpets from countries with low wages. In the electronics sector, it concerns solar panels, smartphones, laptops, wiring harnesses for cars as well as rechargeable batteries, especially when raw materials such as cobalt come from the Democratic Republic of the Congo. Raw materials and construction materials such as natural stone, bricks, sand, cement and metals such as gold, mica, lithium, tin and tungsten from conflict-affected regions are also affected. These estimates are based on the US "List of Goods Produced by Child Labour or Forced Labor" report published in 2024. The EU plans to publish a risk database by 2027 that specifically names such industries and products.
Important: This ban applies across all sectors and to all companies, regardless of size, turnover or legal form. Unlike certain due diligence laws, for example, which only apply to large companies, the Forced Labour Regulation covers all economic actors: producers, manufacturers, importers, suppliers, distributors and exporters. Every company that imports, places on the market or exports products must ensure that no forced labour is involved in its supply chain.
What is "forced labour"?
The regulation is based on the internationally recognised definition of the International Labour Organisation (ILO). According to this definition, forced labour is "any work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily". In practice, this includes, for example, cases in which workers are forced to work through violence, threats, debt bondage, the withholding of identity documents or the withholding of wages. Companies should be aware of these criteria in order to identify risks of forced labour in their supply chains.
Implementation and enforcement of the ban
The EU Forced Labour Regulation will be enforced by national authorities of the Member States in cooperation with customs authorities. They will follow a risk-based approach and use information from various sources, including reports from NGOs, company audits and a database on high-risk products and regions planned by the EU Commission. If forced labour is suspected, the authorities can initiate investigations – if confirmed, the product concerned will be withdrawn from the market throughout the EU.
Although small and medium-sized enterprises (SMEs) are not exempt in principle, the legislator promises a proportionate application: The authorities are to take company size and resources into account in their inspections before launching formal investigations. Nevertheless, this does not exempt SMEs from the obligation not to sell products from forced labour – it merely eases the administrative pressure compared to large companies.
To support implementation, the EU Commission is planning to publish guidelines with specific due diligence obligations and risk indicators. In addition, an "EU Forced Labour Product Network" will be set up to improve the exchange and coordination between national authorities and the EU Commission. These measures are intended to ensure that the regulation is enforced effectively and uniformly throughout the EU.
What should companies do now?
Even though the ban will not come into force until the end of 2027, companies should take action now to make their supply chains free of forced labour. Preparations for the Forced Labour Regulation can be integrated into existing compliance and sustainability processes.
The following steps are recommended:
Supply chain risk analysis and transparency: Get a precise overview of your supply chains. Identify potentially risky products, materials, manufacturers and countries of origin. Industry reports, NGO research and the forthcoming EU risk database can provide information on risk areas.
Active supplier management: Work closely with your suppliers to rule out forced labour. Communicate your expectations clearly and integrate appropriate codes of conduct or contractual clauses against forced labour. If necessary, existing supply contracts should be reviewed and adapted to enshrine rights to audits or extraordinary termination in the event of violations. Together with your suppliers, you can plan improvement measures – such as training, independent audits or switching to trustworthy suppliers.
Expand due diligence processes: Build on existing processes (e.g. from the German LkSG) and integrate forced labour audits into your compliance management. This includes the monitoring of risk indicators (e.g. unusually low prices, indications of abuses) and fixed processes for investigating suspicious circumstances. Establish internal responsibilities – for example, a team or officer for supply chain compliance.
Documentation and verification: Record your efforts in writing. Keep records of risk analyses, discussions with suppliers, audit reports and measures taken. Complete documentation helps to prove that you are exercising due diligence in the event of an enquiry by the authorities. The EU Commission will provide practical guidelines on this that you can incorporate into your processes.
By acting proactively, companies can avoid reputational risks and prepare for the stricter requirements. In addition, a forced labour-free supply chain strengthens the trust of customers and business partners in your company.
Conclusion: Take precautions now – we will support you!
From 2027, the new EU Forced Labour Regulation will close a crucial gap in the fight against modern slavery: for the first time, it will be illegal to trade products made from forced labour across Europe. Companies are well advised to use the transitional period until it comes into force to scrutinise their supply chains and implement appropriate compliance measures. Those who act early will minimise the risk of business disruptions – such as product seizures by the authorities – and at the same time meet the increasing expectations of responsible supply chain management.
Contact us to arrange a non-binding consultation – together we will develop a strategy to ensure that your company is legally compliant and ethically sound from 2027 onwards.
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Since 2018, I have been working at EurA as a sustainability consultant and have been leading the services division, currently comprising 12 team members, since 2020. In parallel, I manage our greenhouse gas verification body, accredited since 2024, and support the development of sustainable investment projects as a GHG assessor (EU Innovation Fund) and expert for Green Assist (EU LIFE). After studying chemistry at the University of Jena, I completed a PhD as part of a DBU scholarship, focusing on integrating sustainability criteria into research, development, and education. As a postdoctoral researcher, my work centered on the environmental assessment of chemical and pharmaceutical processes. Driving sustainability throughout the full lifecycle of products, processes, and innovations – from the initial idea to market entry – gives me a deep sense of purpose. I truly value the inspiring exchange with clients and partners. In my free time, I enjoy being in nature, reading, or discovering new culinary specialities.
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