On 12 December, the EU Forced Labour Regulation (“Regulation”) was published in the EU Official Journal. The publication is following the EU Council’s approval of the Regulation on 19 November 2024. The text of the Regulation was approved by qualified majority with 25 EU Member States voting in favour and 2 EU Member States abstaining from voting. The Regulation was signed by the President of the European Parliament and the President of the EU Council on 27 November 2027. The Regulation can be found here.
Under the Regulation, all products (including their components) manufactured using forced labour will be banned from being placed or made available on the market in the EU, or exported from the EU.
This prohibition will apply to products regardless of the sector, origin, or whether they are made domestically or imported, and also applies to each stage of a product’s supply chain, including its manufacture, harvest and extraction, and any working or processing related to the products. The prohibition will be enforced by risk-based investigations led by the European Commission and EU Member States.
The Regulation entered into force on 13 December 2024 and will apply 36 months later, meaning that companies should be ready for application of the Regulation as of 14 December 2027. We recommend that companies begin to implement robust and effective compliance processes to address forced labour risks in their operations and value chains.
The European Commission will also publish guidelines to assist companies with their compliance efforts. These guidelines (including due diligence guidelines, risk indicators, best practices and penalties) will be made available latest on 14 June 2026.
Please find our previous blog posts on the scope of the Regulation, including more information on the investigatory authority of the European Commission and Member State national competent authorities here and here.
For information on the key similarities and differences between the existing US forced labour regime and proposed EU approach and how companies can best prepare and ensure compliance across their supply chains, please see our Forced Labour Webinar, hosted by Jessica Mutton, Chandri Navarro and Esmee Kooke available here.
