EU Forced Labour Regulation

The EU Forced Labour Regulation (Regulation (EU) 2024/3015) prohibits economic operators from placing or making available on the EU market, or exporting from it, any product made wholly or in part with forced labour. It was adopted by the European Parliament in April 2024, approved by the Council in November 2024, and published in the Official Journal in December 2024. Most provisions become applicable three years after entry into force.

Unlike the US Uyghur Forced Labor Prevention Act (UFLPA), the EU regulation does not target a specific country or create a rebuttable presumption tied to a region. Instead, it applies horizontally to all products and all sectors, regardless of origin, and covers both imports and goods produced inside the EU.

Key mechanics:

• The European Commission leads investigations where forced labour risks involve third countries; national competent authorities in member states lead where the risk is domestic.
• A Forced Labour Single Portal and a Commission-maintained database of risk areas and products support risk-based enforcement.
• A preliminary investigation phase precedes a formal investigation; if forced labour is established, authorities issue a decision requiring withdrawal from the market, prohibition of export, and disposal (recycling, rendering inoperable, or destruction).
• Decisions are mutually recognised across member states, and customs authorities enforce at EU borders.
• The definition of forced labour follows ILO Convention No. 29 (1930), including state-imposed forced labour.

The regulation complements the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD) but is distinct: CSDDD imposes due-diligence obligations on companies, while the Forced Labour Regulation is a market-access ban enforced by public authorities. SMEs receive lighter procedural treatment but are not exempt from the prohibition itself.