EU Forced Labour Regulation

Why should I read this?

The European Commission has published Guidelines to support preparations for the EU Forced Labour Regulation (FLR), which will apply from 14 December 2027. 

Businesses (referred to in the FLR as “economic operators”) supplying any products into, within or out of the EU, including both EU and non-EU businesses, will potentially fall within the FLR’s scope. The FLR introduces a far-reaching prohibition on products made wholly or partly with forced labour at any stage of the supply chain and gives authorities extensive powers to investigate, prohibit and, in some circumstances, require disposal of affected products.

The significance of the FLR goes beyond legal compliance. It represents a major shift towards using trade and market-access restrictions to drive human rights outcomes across global supply chains. It also reflects a broader regulatory direction of travel in which human rights, sustainability and responsible sourcing are increasingly being enforced through stringent trade, customs and market-access tools. 

In this briefing, we examine the Guidelines and outline the steps that companies can take now to prepare.

What do I need to know?

The European Commission estimates that 27.6 million people worldwide are in situations of forced labour. Forced labour comprises work or services extracted from a person under coercion and for which the person has not offered themselves voluntarily, which mirrors the definition in the ILO Forced Labour Convention.

On 14 December 2027, businesses will become legally responsible for ensuring products made with forced labour are not placed on the EU market, made available within it, or exported from it. On the same date, regulators gain the power to investigate and enforce that prohibition. Following a call for evidence in early 2026, the European Commission published Guidelines that clarify how the FLR will be applied in practice, including details of risk indicators to help businesses identify forced labour. The Guidelines also confirm that enforcement will be risk-based, with authorities expected to prioritise cases where the scale and severity of suspected forced labour are greatest.

In practical terms, the FLR turns supply-chain transparency into an operational requirement. Businesses will need not only to understand where products and components come from, but also to be able to evidence how any forced labour risks have been identified, assessed and addressed.

The FLR has a deliberately broad scope, applying:

• to all products, across all sectors and geographies, including agricultural products, manufactured goods, minerals and other extracted raw materials

• to both EU and non-EU businesses supplying products into, within or out of the EU market

• to products made ‘in whole or in part’ with forced labour

• where the forced labour is used at any stage of extraction, harvesting, production or manufacturing of the product, including in its working or processing at any stage of its supply chain

• regardless of turnover, employee numbers or product-value

• to all products that are placed or made available on the EU market as from 14 December 2027, even if the products or their components were produced or imported into the EU before that date

• to products offered for sale online or through other means of distance sales if the sale offer is targeted at end users in the EU

The breadth of the regime means that FLR readiness should not be treated as a narrow legal project. It will require coordination across legal, compliance, ESG, procurement, trade, customs, logistics, sustainability reporting, finance and crisis-management functions.

Key aspects of the Guidelines

• Recommended due diligence framework: Neither the FLR nor the Guidelines impose standalone due diligence obligations. However, the Guidelines strongly encourage a risk-based supply-chain due diligence approach as an effective means of identifying, preventing and addressing forced labour risks and demonstrating compliance efforts. Building on the OECD's six-step due diligence framework, the Guidelines recommend integrating forced labour considerations into policies and management systems, monitoring effectiveness, maintaining appropriate records and supporting remediation where adverse impacts are identified.
  
  Businesses should also consider the FLR alongside wider ESG and supply-chain obligations. For some organisations, separate due diligence requirements may arise under other legal frameworks, including the Corporate Sustainability Due Diligence Directive (CSDDD), subject to its final implementation and any future amendments, while forced labour risks may also need to be addressed through sustainability reporting, modern slavery compliance and responsible sourcing programmes.

• Forced labour risk indicators: The Guidelines provide a range of indicators to help identify forced labour risks, including forced recruitment practices, excessive working hours, restrictions on movement, withholding of wages, intimidation, coercion and degrading working conditions. They emphasise the importance of assessing risks throughout the supply chain, particularly where there are known sectoral, geographic or worker-vulnerability risks.

• Supply chain information: The Guidelines set out a non-exhaustive list of information that authorities may request during investigations, including supply-chain maps, risk assessments, due diligence records, sourcing information, audit findings and remediation records. Businesses should ensure they can readily access and provide this information.

• Risk-based prioritisation: The Guidelines indicate that authorities should prioritise products by reference to the scale and severity of suspected forced labour, the volume of products made available on the EU market and the share of the relevant component suspected to have been made with forced labour. For economic operators, authorities will also consider proximity to the alleged forced labour, leverage, size and economic resources. Suspected state-imposed forced labour is likely to be treated as particularly significant for scale and severity.

• Investigations and enforcement: Competent authorities are given extensive investigative powers and may require the withdrawal, prohibition, disposal or replacement of products found to have been made with forced labour. Enforcement decisions will be published through the Forced Labour Single Portal and may affect not only the business under investigation but also other operators dealing in the same products. The potential operational, financial and reputational consequences mean that FLR compliance should form part of wider supply-chain risk governance.

• Compliance tools: The Commission has launched a Forced Labour Single Portal which will be a reference point for guidance, training materials and other compliance resources. It is also developing a Forced Labour Risk Database identifying products, sectors and geographic areas where credible evidence of forced labour exists. Both resources are expected to become important tools for businesses assessing and monitoring forced labour risks.

What should I do next?

Any business that manufactures, sources, imports, distributes, sells or exports products connected to the EU market should assess its operations now. Mapping complex product supply chains, obtaining reliable information from suppliers, renegotiating contractual protections, improving traceability and embedding escalation processes can take considerable time. 

In particular, businesses should:

• Audit and map. Map product supply chains and identify where forced labour risks may arise, including at raw material, manufacturing, processing and logistics stages. Prioritise products by risk, value, strategic importance and difficulty of substitution. Focus on higher-risk product areas, including, for example, batteries and battery raw materials, cotton and textiles, solar-grade polysilicon, and respective downstream products (aluminium, steel, copper, lithium and seafood), and stress-test FLR readiness.

• Assess and integrate checks. Assess the risks using recognised indicators and integrate forced labour checks into procurement, supplier onboarding, contract terms, audit rights and risk management processes. Consider whether supplier codes of conduct, modern slavery statements, ESG policies and contractual audit/remediation rights are sufficiently specific to forced labour risk.

• Action and review. Where risks are identified, take appropriate steps to prevent, mitigate or eliminate them, keep evidence of the decisions taken, monitor suppliers on an ongoing basis, and be ready to provide information to competent authorities if requested. Also review product withdrawal and crisis-response processes, as enforcement action may require affected products to be withdrawn, disposed of or replaced.

• Strengthen evidence and data systems. Ensure that supply-chain maps, risk assessments, supplier responses, audit findings, training records, escalation decisions and remediation steps are retained in a format that can be retrieved quickly if a regulator requests information.

• Integrate. Forced labour due diligence should be integrated into existing compliance frameworks, procurement processes and risk management systems.

• Monitor. Developments are likely to continue in the lead up to 14 December 2027, including in relation to the Forced Labour Risk Database and Single Portal, which are likely to become key compliance resources before the Regulation takes effect. 

Further reading/resources

How we can help

Our teams have extensive experience in advising clients on the complex and rapidly evolving cross-jurisdictional regulatory landscape of trade and sustainability, including its implications for global supply chains. We can support businesses in taking a practical and proportionate approach to FLR readiness, including by:

• assessing whether products, suppliers or geographies are likely to create higher FLR exposure

• designing risk-based supply-chain due diligence frameworks

• reviewing supplier contracts, procurement policies, audit rights and remediation processes

• aligning FLR readiness with CSDDD, CSRD, modern slavery and wider ESG governance frameworks

• supporting board and senior-management briefings on supply-chain human rights risk

• preparing regulator-response protocols and product withdrawal playbooks; and

• helping businesses respond to investigations, stakeholder scrutiny or potential forced labour concerns