Guidelines on the EU Forced Labour Regulation

Commission Notice – Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market

Update

In September 2026, the European Commission published new Guidelines on the application of Regulation 2024/3015 (the Forced Labour Regulation), which will apply from 14 December 2027. The Regulation prohibits operators from placing products made using forced labour on the European Union (EU) market, and prohibits the export of such products from the EU.

These Guidelines are not legally binding (only the Regulation itself is legally binding) and are intended to help stakeholders comply with the new rules.

Impacted Products

All products

What is changing?

The European Commission has published Guidelines for implementing the Forced Labour Regulation 2024/3015. The new Guidelines aim to help stakeholders apply the new rules, including:

• competent authorities – on the practical implementation of the Regulation
• businesses – on due diligence related to forced labour (e.g. monitoring, auditing, and documentation of labour practices along the supply chain)
• civil society organisations, victims, and other stakeholders – on how to submit information regarding potential violations of the ban.

These Guidelines are not legally binding (only the Regulation itself is legally binding). They aim to clarify the requirements of the Forced Labour Regulation, including the following:

• Scope of the Regulation (Chapter 3 of the Guidelines). The ban applies to:
  • all products made with forced labour, irrespective of the type of product and where it was produced, and even if only part of the product was made using forced labour
  • forced labour at any stage of extraction, harvesting, production, or manufacturing, including different parts of the supply chain
  • both products placed on the EU market and products exported from the EU.
• Definition and types of forced labour (Chapter 3).
• Risk indicators that authorities and companies can use to identify potential forced labour (Chapter 3).
• Investigation process (Chapter 4):
  • authorities are recommended to follow a staged, evidence-based process: (1) identify risk; (2) carry out preliminary assessment; (3) assess if there is a substantiated concern; (4) launch formal investigation; (5) make decision on violations; (6) consider any request for review or appeal
  • if suspected forced labour takes place outside the EU, investigations and decisions should be made by the European Commission.
• Enforcement and penalties (Chapter 5):
  • if a product is banned, competent authorities can require businesses to withdraw or dispose of affected products, restrict access to them, and remove online listings (perishable products should be donated)
  • customs authorities can identify and stop affected products at the border once they have been notified of a prohibition decision
  • penalties can be allocated based on the nature, gravity, and duration of non-compliance.
• Applying due diligence to avoid products made using forced labour (Chapter 6):
  • the Regulation does not prescribe one mandatory compliance system
  • the Guidance sets out a due diligence process for companies: (1) integrate forced labour due diligence into internal procedures, risk management systems, and training, (2) identify and assess forced labour risks in their own operations and supply chains, (3) prevent or at least mitigate forced labour, (4) monitor implementation and results in their own and suppliers’ operations, (5) provide appropriate remediation to people who have been adversely affected and cooperate in remediation processes.
• Third parties can report concerns and provide information about possible forced labour violations (Chapter 7).

For further information on the Regulation, see Prohibition of products made with forced labour.

Why?

The Forced Labour Regulation (2024/3015, Art. 11) requires the European Commission to publish implementation guidelines to help competent authorities, businesses, and stakeholders apply the Regulation in a practical and effective way, while also reducing the burden on administrations and companies.

Timeline

The Forced Labour Regulation will apply from 14 December 2027.

What are the major implications for exporting countries?

Exporters and producers in non-EU countries will need to ensure that their supply chains are free from forced labour. This may require enhanced monitoring, auditing, and documentation of labour practices across all suppliers and subcontractors.

Countries participating in EU trade schemes such as the Generalised Scheme of Preferences and Economic Partnership Agreements may see their market access affected if forced labour risks are not mitigated.

Recommended Actions

Non-EU suppliers and importers are advised to put in place monitoring and reporting systems that will reduce the risk of investigations by their EU buyers on the use of forced labour.

Background

Forced labour is a global issue that violates human dignity and fundamental rights, and perpetuates poverty, obstructing the Sustainable Development Goal of decent work for all. The International Labour Organization estimates that 27.6 million people are subject to forced labour (ILO et al. 2022). Recognised by the ILO as a fundamental rights principle, its elimination requires international cooperation across interconnected global supply chains.

The EU Forced Labour Regulation has been in force since 13 December 2024, and will apply from 14 December 2027. It prohibits businesses from placing on the EU market, or exporting, products made with forced labour. To ensure effective implementation, the European Commission will cooperate and exchange information with non-EU authorities, international organisations, civil society, trade unions, and business groups. Cooperation will be structured through existing frameworks including human rights and political dialogues, trade and sustainable development dialogues, the Generalised Scheme of Preferences, and EU development initiatives.

Resources

Sources