VOL I · NO I · JULY 2026

The tracker · European Union

EU Forced Labour Regulation

Pending European Union Entry updated April 2026

A market prohibition on products made with forced labour at any stage of the supply chain, applying from December 2027.

StatusPending
EnactedDecember 2024
First compliance deadline14 December 2027
Companies in scopeAll economic operators placing products on the EU market, regardless of size
Maximum penaltyProduct withdrawal, disposal and member state penalties
Civil liabilityAdministrative product ban rather than civil liability
Enforcement bodyNational competent authorities and the Commission for third country cases

Latest movement

Commission building the forced labour risk database ahead of application in December 2027.

In plain language

What this law does

The regulation prohibits placing or making available on the EU market, or exporting from it, any product made wholly or in part with forced labour. Unlike the American UFLPA it carries no rebuttable presumption against a named region; investigations are risk-based, led by national authorities for domestic cases and by the Commission where the suspected forced labour occurs outside the EU.

Because there is no de minimis threshold and no company size cut-off, the regulation reaches every exporter selling into the EU. The Commission is currently building the risk database and guidance that will shape early enforcement priorities before obligations apply in December 2027.

Obligations

What it asks of companies

  1. Market prohibition

    Products made with forced labour at any tier cannot be sold on, or exported from, the EU market.

  2. Cooperation with investigations

    Operators must respond to information requests and evidence demands from investigating authorities within set deadlines.

  3. Withdrawal and disposal orders

    Where forced labour is established, products must be withdrawn, donated, recycled or destroyed at the operator cost.

Timeline

How it got here

December 2024

Regulation adopted and entered into force.

2025 to 2027

Commission preparing the risk database, guidelines and the Union Network Against Forced Labour Products.

14 December 2027

Prohibition and enforcement powers apply.

Changelog

Entry history

April 2026

Entry updated with progress on the Commission risk database and draft guidance.

Sources

Primary documents

Same jurisdiction

Related regimes