European UnionDelayed
Corporate Sustainability Due Diligence Directive
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
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A market prohibition on products made with forced labour at any stage of the supply chain, coming into force in December 2027
Commission published its enforcement guidelines on 30 June 2026, alongside a provisional list of national competent authorities.
In plain language
The EU FLR bans the sale of goods made with forced labour anywhere in the supply chain, applying to companies of all sizes with no exemption for smaller entities. Unlike the approach taken by the United States with the Uyghur Forced Labor Prevention Act (UFLPA), the EU FLR does not treat an entire region as presumptively guilty. Instead, EU authorities investigate specific cases, weighing the severity of the suspected harm, the volume of goods involved, and how significant forced labour is to the finished product.
In cases where goods are flagged for suspected forced labour, EU customs authorities can seize and order the destruction of the shipment. Companies under investigation are expected to produce evidence covering their full supply chain, which creates pressure to obtain that evidence from suppliers in advance. It is critical here to note that suppliers will not be able to rely solely on certifications and voluntary standards to prove their compliance to the regulation.
The EU FLR's ban on goods with forced labour in their supply chains applies from December 2027. The European Commission published its enforcement guidance on the 30th of June 2026, outlining the evidence authorities will expect and how investigations will be conducted.
Obligations
Products made with forced labour at any tier cannot be sold in, or exported from, the EU market
Operators must respond to information requests and evidence demands from investigating authorities within set deadlines.
Where forced labour is established, products must be withdrawn, donated, recycled or destroyed at the operator cost.
Timeline
Regulation Adopted
Commission preparing the risk database, guidelines and the Union Network Against Forced Labour Products.
Commission published its Guidelines on the Forced Labour Regulation, covering due diligence, risk assessment, enforcement and penalties, alongside a provisional national competent authority list.
Prohibition and enforcement powers apply.
Changelog
Entry updated with progress on the Commission risk database and draft guidance.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Sources
Same jurisdiction
Omnibus I in force since March 2026; transposition due July 2028 and application from July 2029.
Read →Omnibus narrowed scope to 1,000 employees from FY2027; first wave reporting continues with opt-outs.
Read →Second postponement published one week before application; large operators now start on 30 December 2026.
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