The EU forced labour ban (Regulation 2024/3015): what buyers must prepare before December 2027

Trade, law & sustainability · By the Buyer's Ledger editorial team · Published 2026-11-02

A cotton picker working in a field at sunset under an orange sky — The regulation reaches every stage of a product's supply chain, from harvesting raw materials such as cotton to the finished goods a buyer orders.

From 14 December 2027, no product made with forced labour may be placed on the EU market, made available on it or exported from it. The rule applies to every product and every company, whatever its size, and enforcement works product by product: an investigation can end with goods withdrawn and destroyed. For procurement teams, the thirteen months that remain are the time to find out what they would be able to show an authority about their supply chains.

What the regulation says

Regulation (EU) 2024/3015 was adopted on 27 November 2024 and published in the Official Journal on 12 December 2024. Its core is a single sentence, Article 3: economic operators "shall not place or make available on the Union market products that are made with forced labour, nor shall they export such products."

The definitions make the reach clear:

Forced labour takes the meaning of Article 2 of ILO Convention No 29, including forced child labour. The regulation also refers separately to forced labour imposed by state authorities, as described in ILO Convention No 105.
A product made with forced labour is one for which forced labour was used "in whole or in part at any stage of its extraction, harvest, production or manufacture", including processing anywhere in the supply chain. A component or raw material is enough.
An economic operator is any person or company placing or making available products on the EU market, or exporting them: manufacturers, importers, distributors and retailers alike.
Online sales count as making a product available in the EU when the offer is targeted at end users in the Union (Article 4).

The regulation does not order the recall of products already in end users' hands, and Article 1 states that it creates no additional due diligence obligations beyond those in existing EU or national law. In practice, however, the information an authority will ask for is due diligence information, so the two cannot be separated.

Why buyers should care

The International Labour Organization's Global Estimates of Modern Slavery, published in September 2022, counted about 28 million people in forced labour in 2021. The ILO attributes about 86% of cases to the private economy and about 14% to forced labour imposed by state authorities. Exposure is rarely visible at tier one: it tends to sit in raw materials and early processing, several steps upstream of the supplier a buyer actually contracts with.

How enforcement works

There is no certification or pre-approval. Authorities act on risk, and the process runs in stages.

Who investigates

Where the suspected forced labour takes place outside the EU, the European Commission leads; where it takes place in a member state, that state's competent authority leads (Article 15). Member states had to name their authorities by 14 December 2025.

Risk-based selection

Authorities prioritise cases using the scale and severity of the suspected forced labour, the quantity of products placed on the EU market and the share of the suspect part in the final product (Article 14). They draw on a Commission database of risk areas and products, submissions from third parties and other authorities' information. When opening a case, they are told to focus on operators as close as possible to where the forced labour is likely to occur, and to take account of company size, especially for SMEs.

The preliminary phase

Before opening a formal investigation, the lead authority asks the operators concerned what they have done to identify, prevent, mitigate, bring to an end or remediate forced labour risks for the products in question (Article 17). Operators have 30 working days to answer. The authority then has 30 working days to decide whether there is a "substantiated concern".

Investigation and decision

If it opens an investigation, the authority informs the operators within three working days and can request detailed information, setting a deadline of between 30 and 60 working days (Article 18). It should aim to decide or close the case within nine months (Article 20). An operator that refuses to answer, answers late without justification or provides misleading information can be found in breach on the basis of the other facts available.

A decision finding a breach prohibits placing, making available and exporting the products, orders their withdrawal and orders their disposal (Article 20). Operators get a time limit of at least 30 working days to comply, or at least 10 for perishable goods (Article 22). Disposal means recycling or, failing that, rendering the products inoperable; perishable products are donated for charitable or public interest purposes where possible (Article 25). Where a replaceable part is at fault, the order can target that part. For supply chains of strategic or critical importance, the authority may instead order the products withheld while the operator eliminates the forced labour.

Decisions taken in one member state are recognised in the others, customs authorities use them to stop the products at the border, and operators can ask for a review at any time with substantial new information (Articles 20, 21 and 26). Penalties for failing to comply with a decision are set nationally; member states must notify their rules to the Commission by 14 December 2026 (Article 37).

What is already available

Several provisions have applied since 13 December 2024 so that the system is ready in time (Article 39). Article 11 required the Commission to publish guidelines by 14 June 2026, covering due diligence on forced labour, risk indicators, forced labour imposed by state authorities and how to engage with authorities, with a particular focus on SMEs. The Commission's Forced Labour Regulation page lists the launch of a preparedness package and the Forced Labour Single Portal on 30 June 2026, and links to the guidelines, the risk database and the lists of competent authorities. The database is indicative and non-exhaustive, and it does not name individual companies (Article 8).

A preparation plan for procurement

Map where your products come from. Start with the categories most exposed to risk: raw materials, agricultural inputs and labour-intensive manufacturing. You cannot answer an authority's questions about a supply chain you have never traced. Our guide to supply chain due diligence sets out the OECD-based method; OECD due diligence guidance is among the references the regulation tells authorities to consider when they question operators (Article 17).
Screen against the database and guidelines. Compare your supplier and sourcing-region map with the Commission's risk database and risk indicators, and record what you found and when.
Write it into contracts. Add clauses requiring suppliers to provide traceability information, allow audits, flow the same requirements upstream and notify you of risks. Agree in advance who bears the cost of withdrawal and disposal if a decision hits a product.
Prepare a 30-working-day file. For each high-risk product, keep a ready-to-send record of origin, suppliers by tier, assessments, audits and corrective actions. Thirty working days is about six weeks: too short to start from zero.
Plan for disruption. Identify alternative sources for exposed inputs, as you would for any other supply risk; see our supplier risk and resilience framework.
Prefer remediation to exit. Article 11 requires the guidelines to cover best practices for bringing forced labour to an end and remediating it. Walking away from a supplier at the first sign of risk can leave workers worse off and does not, by itself, clean up products already in your pipeline.

Sources

Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labour on the Union market, Official Journal of the European Union, L series, 12 December 2024.
European Commission, Forced Labour Regulation (single-market-economy.ec.europa.eu), consulted November 2026.
International Labour Organization, Walk Free and IOM, Global Estimates of Modern Slavery: Forced Labour and Forced Marriage, September 2022.
ILO Forced Labour Convention, 1930 (No. 29) and Abolition of Forced Labour Convention, 1957 (No. 105).