What does the EU forced labour regulation change, and when?
From 14 December 2027, products made with forced labour can no longer be placed on the EU market, made available there or exported from it (Article 3). Regulation (EU) 2024/3015 of 27 November 2024, published in the Official Journal on 12 December 2024, entered into force the next day; the ban, investigations and decisions only apply from December 2027 (Article 39).
Three rules of the text, read on EUR-Lex on 11 November 2026, set its reach:
- Definition. Forced labour is defined by Article 2 of the International Labour Organization (ILO) Forced Labour Convention No. 29, including forced child labour (Article 2).
- Any stage. A product is « made with forced labour » if forced labour was used, in whole or in part, at any stage of its extraction, harvesting, production or manufacture, processing included. According to the guidelines, the size of the affected part does not matter.
- No new due diligence. The regulation creates no additional due diligence obligation (Article 1, paragraph 3).
Date | Milestone | Basis |
|---|---|---|
13 December 2024 | Entry into force | Article 39 |
14 December 2025 | Member States communicate their competent authorities | Article 5(3) |
14 June 2026 | Deadline for the Commission guidelines and database | Articles 8 and 11 |
30 June 2026 | Launch of the Forced Labour Single Portal and preparedness package | European Commission |
3 September 2026 | Guidelines published in the Official Journal (C/2026/4637) | EUR-Lex |
14 December 2026 | National penalty rules notified to the Commission | Article 37(3) |
14 December 2027 | Ban, investigations and customs controls apply | Article 39 |
On 11 November 2026, the Commission page on the database of risk areas and products still read « Database in development », despite the 14 June 2026 deadline set by Article 8.
Who is covered by the EU forced labour ban?
Any economic operator that places a product on the EU market, makes it available there or exports it, whatever its size: importer, manufacturer, distributor, or online seller whose offer targets EU users (Articles 2 to 4). Manufactured, agricultural and extracted products are covered. The guidelines exclude services, even product-related ones: transport, warehousing, logistics.
The ban also covers products placed on the market after 14 December 2027 that were made or imported before that date.
Exporters in Morocco, Africa and the Middle East
A garment maker in Tangier or a wiring-harness plant in Kenitra, Morocco, is usually a « supplier of the product » (Article 2(12)): its EU importer answers for the ban. Three rules still reach the supplier directly:
- The Commission investigates itself when the suspected forced labour takes place outside the EU (Article 15).
- Requests can target you. The authority questions operators and, where relevant, other suppliers of products (Article 17); the guidelines name suppliers established outside the EU. It focuses first on the actors closest to where forced labour is likely to occur, taking their size into account (Article 14(4)).
- An on-site inspection outside the EU requires your consent and no objection from the government of the country, which must be officially informed (Article 19).
What will your EU buyers ask you for?
The evidence the authority can require from them. Section 4.7 of the guidelines gives three non-exhaustive families of examples:
Type of information | Examples given by the Commission | What you prepare |
|---|---|---|
Measures taken against forced labour | Policies and codes of conduct, training, contract clauses, supplier onboarding and monitoring, grievance mechanism, multi-stakeholder or industry certification, third-party audit reports | Signed policy, training records, clauses passed on to your own suppliers, grievance log |
Working conditions on site | Worker interviews, social audits, worker lists, contracts, payslips, remediation measures | Up-to-date HR and agency-worker files, proof of wage payment, corrective action plan |
Product and supply chain | HS or CN codes, batch numbers, bills of materials, map of direct and indirect suppliers, sites and geolocation, purchase orders, invoices, shipping documents, consistency between inputs and output | Batch-level traceability, list of raw-material suppliers, material balances per period |
Deadlines are short: 30 working days to answer in the preliminary phase (Article 17), then 30 to 60 working days during an investigation (Article 18). A refusal, an unjustified delay or misleading information lets the authority decide on the other data available (Article 20(2)). Conversely, the Commission notes that providing these documents does not guarantee clearance.
To guide your self-assessment, the guidelines use the ILO indicators, including abuse of debt, withholding of wages, retention of identity documents, restriction of movement, excessive working hours and deception at recruitment.
What penalties apply to a non-compliant product?
The first penalty falls on the product. The authority bans placing it on the market and exporting it, orders its withdrawal and its disposal, by recycling or by rendering it unusable (Articles 20 and 25). It aims to conclude within nine months. Customs then check products covered by a decision (Article 26). Penalties set by each Member State punish failure to comply with the decision (Article 37). The decision is withdrawn if the operator proves it has removed forced labour from its supply chain (Article 21).
What should suppliers do now?
- By the end of 2026: map your flows. List the products you sell into the EU, your importing customers and the materials you buy, by country of origin.
- In the first half of 2027: map your risks. Agency work, subcontractors, migrant workers, high-risk materials; use the ILO indicators and, once online, the Commission database.
- Before summer 2027: pass your requirements on. Code of conduct and forced labour clauses with your own suppliers, using ISO 20400:2017 sustainable procurement.
- Before 14 December 2027: be ready to answer within 30 working days. An indexed evidence file and a named contact person, as the guidelines recommend.
- Then: follow the Single Portal. Ban decisions and their withdrawals are published there (Article 12).
Your minimum evidence file:
The CSDDD will ask the largest groups for a similar file from 2029: see our article on the CSDDD Omnibus timeline for suppliers. For plot-level traceability, see our article on the EUDR deforestation regulation.