Regulation (EU) 2024/3015
EU Forced Labour Regulation: what is banned from 14 December 2027
A market ban instead of a reporting duty — who is affected and how you prove origin.
Status: ban applies from 14 Dec 2027 — no size threshold, all economic operators
Relevant for: every company placing products on the EU market or exporting them
What is the EU Forced Labour Regulation?
The EU Forced Labour Regulation (Regulation (EU) 2024/3015, EUFLR) prohibits, from 14 December 2027, placing products made wholly or partly with forced labour on the EU market, making them available, or exporting them from the EU. It is neither a reporting law nor a due diligence obligation in the narrow sense. It is a market ban that applies to every product and every company.
The core is Article 3:
“Economic operators shall not place or make available on the Union market products that are made with forced labour or export such products.” — Art. 3 Regulation (EU) 2024/3015
The regulation defines forced labour via ILO Convention No. 29: all work or service exacted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily. This includes forced child labour.
Who is affected?
Every company that places products on the EU market, makes them available or exports them. The regulation deliberately sets no size threshold, no turnover limit and no sector list:
- Manufacturers of finished products, even if the forced labour risk sits in only one component or raw material.
- Importers and distributors, including online retail; distance selling to EU customers counts as making available.
- Exporters selling out of the EU.
- Suppliers whose parts end up in an affected end product are reached via customer requests.
The regulation is product-based, not company-based. It follows the same logic as EUDR and CBAM: the origin of the goods decides, not the size of the company.
Not affected: pure services without a product. Everyone else is affected, even though authorities consider company size, the extent of the suspicion and the quantity of products when selecting investigations.
What applies from when?
| Date | What applies |
|---|---|
| 13 Dec 2024 | Entry into force |
| 26 Jun 2026 | Commission guidelines on due diligence, risk indicators and procedures published |
| 14 Dec 2027 | Ban applies; authorities can open investigations and remove products from the market |
Until then, the Commission is building a database of forced labour risks by region and product group and setting up the single portal for submissions. In Germany, the competent authority is designated by implementing legislation.
Which concrete obligations arise?
The regulation prescribes no processes. It creates a ban with burden of proof in case of suspicion. In practice, four tasks follow:
- Know the origin: for every product, know where components and raw materials come from, at least at the level of suppliers and their regions.
- Assess risks: identify regions, raw materials and sectors with known forced labour risk (the Commission database and the risk indicators in the guidelines set the frame).
- Document due diligence: supplier assessments, code of conduct, audits, certificates, grievance mechanism, responses to reports. In a preliminary investigation the authority first checks whether the company exercised appropriate due diligence.
- Be able to respond: on request from the authority, deliver information on product, supply chain and due diligence measures within the deadline set (usually 30 working days).
Companies that cannot prove these four points lose not only a batch in case of suspicion, but also the trust of customers who are themselves subject to the regulation.
Common misconceptions
- “We have fewer than 1,000 employees, the LkSG doesn’t apply to us, so neither does this.” The German LkSG has a size threshold, the Forced Labour Regulation does not. It applies to the five-person importer just as it does to the corporation.
- Understanding the regulation as a reporting duty. There is no report you can file to be “compliant”. There is only the question: can I prove, in case of suspicion, where my product comes from and what I checked?
- Only looking at end products. The product is affected as soon as one part of it originates from forced labour: the cotton in the work glove, the polysilicon in the solar module, the tomatoes in the sauce.
- Waiting for the authority. Investigations begin at the end of 2027. Customer requests for proof of origin are already arriving, because OEMs are cleaning up their supply chains in advance.
How SCRM Guard helps
On the platform you record suppliers and commodity groups with region of origin and risk profile. Event monitoring watches news and data sources on forced labour, human rights and sanctions per supplier, region and commodity group and reports hits in Microsoft Teams. Material monitoring resolves products down to raw-material level and shows where cotton, polysilicon, cobalt or other risk materials sit in your products. Supplier assessments, code of conduct confirmations and audit results live in the audit trail you can present to the authority within the deadline.
In the full service we build the origin documentation with you, prioritise suppliers by risk and take over supplier communication. And we tell you which of your commodity groups are low-risk and need no deeper review.
Frequently asked questions
Is there a size threshold or exemption for small companies?
Is the Forced Labour Regulation a reporting law like the German LkSG?
What happens if a product is affected?
How do you prove that a product is free of forced labour?
Sources
- Regulation (EU) 2024/3015 on prohibiting products made with forced labour, EUR-Lex (12 Dec 2024)
- European Commission: Forced Labour Regulation guidelines (26 Jun 2026)
- ILO: Forced Labour Convention, 1930 (No. 29) (definition) (28 Jun 1930)
This page is an editorial briefing for procurement and compliance teams in mid-sized companies, not legal advice. We check deadlines and thresholds against primary sources; the review date is shown at the top of the page.