EU Forced Labour Regulation
Products made with forced labour banned from the EU market from December 2027. Global scope — all products regardless of origin, no company size threshold.
Overview
The EU Forced Labour Regulation — Regulation (EU) 2024/3015 — prohibits products made with forced labour from being placed on the EU market or exported from the EU. Unlike most EU regulations, it has no company size threshold — all economic operators are potentially subject to investigation.
Legal basis
- Proposed: 14 September 2022
- Adopted: November 2024
- Entered into force: 13 December 2024
- Competent authorities designated: 14 December 2025
- Full application: 14 December 2027
Scope
Global scope: Applies to ALL products sold in the EU market or exported from the EU, regardless of geographic origin. There is no turnover or employee threshold.
Key principle: "Rebuttable presumption" — if evidence of forced labour is found, products are presumed non-compliant until proven otherwise.
How it works
No new due diligence obligations are created. Instead:
- National competent authorities conduct investigations based on evidence
- Companies must demonstrate products are not made with forced labour
- Existing due diligence evidence (CSDDD compliance, audits, certifications) creates a presumption of compliance
- Commission handles cases involving substantial forced labour impact
Commission guidance (by 14 June 2026): guidance on due diligence, identifying forced labour risk, database of risks by country and sector.
Who is affected
- All economic operators placing products on the EU market or exporting products from the EU, regardless of company size or sector — there is no turnover threshold and no employee threshold
- EU-based operators (manufacturers, importers, distributors) for products sold within the EU
- Exporters for products leaving the EU
- Coverage extends across the entire value chain — not just direct suppliers; the regulation reaches extraction, harvest, processing, and manufacturing at any tier
- SMEs are in scope but competent authorities are required to consider the size of the operator when setting investigation priorities
Penalties and enforcement
Member States must establish effective, proportionate, and dissuasive enforcement provisions by 14 December 2026. The regulation specifies the following consequences:
- Product withdrawal from the EU market
- Ban on release of products at EU borders (customs hold)
- Confiscation of implicated products
- Disposal of confiscated products at the operator's expense
- Public naming on the Forced Labour Single Portal (Commission-maintained), including the operator's name, date of decision, summary of finding, and penalties imposed
Competent authorities must complete investigations within 9 months (18 months for complex cases involving developing countries). The burden of proof operates as a rebuttable presumption — once forced labour evidence is found, products are presumed non-compliant until the operator demonstrates otherwise.
Risk database
The Commission is required to publish guidance and a risk database by 14 June 2026, identifying:
- Countries and regions with heightened forced labour risk
- Specific economic sectors with systemic forced labour concerns
- Indicators for identifying forced labour practices
This database will serve as the primary reference for competent authority investigations and operator due diligence planning.
Relevance to DPP
While the regulation does not mandate a DPP, DPP infrastructure supports compliance:
- Product traceability data helps demonstrate supply chain provenance
- Supplier information supports investigations
- Companies with robust DPP data can demonstrate transparency
Key dates
| Date | Milestone | |------|-----------| | 13 December 2024 | Entered into force | | 14 December 2025 | National competent authorities designated | | 14 June 2026 | Commission guidance published | | 14 December 2027 | Full application — products made with forced labour banned |