EU Forced Labour Regulation: what applies from December 2027 and what support is already available

What it is about

Regulation (EU) 2024/3015 (the “Forced Labour Regulation”) was published in the Official Journal on 12 December 2024. It prohibits economic operators from placing or making available products made with forced labour on the Union market, or exporting such products (Art. 3). Unlike due diligence laws, it is not linked to the size of the company but to the product. In principle, it covers all products and economic operators, irrespective of sector and origin.

Forced labour is to be understood within the meaning of Article 2 of ILO Convention No 29, including forced child labour. State-imposed forced labour is determined by Article 1 of ILO Convention No 105 (Art. 2(1) and (2)).

Timetable

• Application: The Regulation applies from 14 December 2027 (Art. 39).
• Provisions applying earlier: Since 13 December 2024, the provisions on, among other things, the notification of competent authorities, the information and communication system, the database, the guidelines and the notification of national rules on penalties have applied (Art. 39, third subparagraph).
• Competent authorities: Member States had to notify their competent authorities by 14 December 2025 (Art. 5(3)). The Commission makes the list of notified authorities publicly available and updates it (Art. 5(4)); it can be accessed via the Commission’s “Who to contact” page.
• Rules on penalties: Member States must notify the Commission of their rules on penalties by 14 December 2026 (Art. 37(3)).
• Database and guidelines: Both were due by 14 June 2026 (Art. 8(3), Art. 11).

The Commission’s guidelines

The Commission published its guidelines on the application of the Regulation in the Official Journal on 3 September 2026 (C/2026/4637). They cover, among other things:

• the scope,
• the elements of forced labour (involuntariness, coercion) and the forms of private, state-imposed and child forced labour,
• risk indicators,
• the risk-based approach to selecting investigations,
• the conduct of the preliminary phase and the investigation,
• examples of the information authorities may request on a company’s measures.

For companies, the guidelines matter above all because, in the preliminary phase, authorities ask about the measures taken to identify, prevent, mitigate, bring to an end or remediate forced labour risks. In doing so, they may refer to Commission guidelines and international guidelines, for example from the UN, the ILO and the OECD (Art. 17(1)).

Database of risk areas and products

Art. 8 provides for a public database containing evidence-based information on forced labour risks in specific geographic areas or with respect to specific products. It does not name individual economic operators and is to list economic sectors in geographic areas for which there is reliable evidence of state-imposed forced labour (Art. 8(2)). The Commission’s information page describes the purpose and use of the database. At the time of writing, however, it displayed the notice “Database in development” (accessed 18.10.2026).

Procedure and legal consequences

Where the suspected forced labour takes place outside the EU, the Commission leads the investigation; where it takes place in a Member State, that Member State’s authority does (Art. 15). If a violation is established, a decision is adopted containing three elements (Art. 20(4)):

• a prohibition on placing or making available the products on the market and on exporting them,
• an order to withdraw the products from the market,
• an order to dispose of them in accordance with the waste hierarchy (Art. 25).

Where the affected parts can be replaced, the order may be limited to those parts. Anyone who fails to comply with such a decision faces penalties under national law (Art. 37). Information on possible violations can be submitted via a single submission point of the Commission (Art. 9).

What companies typically examine

1. Product perspective: Which products or components come from regions or sectors with documented forced labour risks?
2. Traceability: Can origin and supply chain be evidenced at an authority’s request?
3. Existing processes: Can LkSG or CSDDD risk analyses be used for the product-related questions?
4. Ability to respond: Who answers requests for information, and within what time limit?

This post provides a general overview of the legal position and does not replace legal advice on individual cases.

← All posts