EU Forced Labour Regulation

Recap: what is EUFLR?

The EU Forced Labour Regulation (EUFLR) is an EU regulation that prohibits placing or making available on the EU market, as well as to export, products made with forced labour. Its aim is to prevent forced and child labour in global supply chains.

All type of products placed, made available in or exported from the EU, regardless of their origin or sector, are subject to the regulation. The progression of an investigation or border seizure, when there is suspicion of forced or child labor in the supply chain, depends on the strength of the due diligence process, proceeding only when the economic operator can not demonstrate that risks have been identified and mitigated effectively. Strong due diligence on high-risk products is therefore essential to avoid shipment delays and supply chain disruptions. This flyer provides insight in the current status of the EUFLR, the obligations that businesses face when selling, importing or exporting products in or from the EU market, and provides key questions to assess your company’s progress towards EUFLR compliance and strategic advantage.

Indicative timeline to prepare for EUFLR

The EUFLR was published in the Official Journal of the European Union on 12 December 2024, with full obligations envisaged to start by 12 December 20271. Businesses should be prepared to demonstrate compliance to prevent bans on importing, selling, or exporting products in the EU, product withdrawals, removal from online sale, and product disposal. Acting now allows you to manage these risks, sidestep last-minute hurdles, and gain long-term advantages from enhanced supply-chain visibility and data.

Depending on the steps already taken and the complexity of your supply chain, preparing for the EUFLR is an extensive process, requiring deep supply chain visibility and engagement. However, when working closely with Procurement, Trade & Operations specialists, your organisation can leverage a lot of the necessary data and engagement efforts.

EUFLR obligations require robust human rights due diligence

To comply with the EUFLR, your business should conduct thorough supply chain due diligence to identify and assess forced labour risks. This will enable early detection of potential irregularities in your product’s supply chain and compliance with EUFLR, while also delivering strategic and commercial advantages:

Creating synergies with other regulations and trade requirements

The EULR has touchpoints with the EU Batteries Regulation (EUBR), CSDDD, U.S. Uyghur Forced Labor Prevention Act (UFLPA), UK Modern Slavery Act (UKMSA) and other upcoming due diligence regulations, particularly in Asia. All obligations require companies to assess and address human rights risks in their supply chains. Adopting a “first-time right” approach based on the UNGPs and OECD Guidelines helps achieving significant synergies and cost savings.

Are you on track to reach compliance and win new markets?

What’s next? The below questions of our readiness assessment facilitate determining your company’s progress towards compliance and identify areas where additional support or acceleration might be needed. That will enable you to show that forced and child labour were not used at any stage.