EU Forced Labour Regulation

Modern slavery and forced labour are still all too common in workplaces around the world, even in the 21st century. In 2021, 27.6 million people were subjected to forced labour. That represents an increase of 2.7 million victims compared to 2016. On 13 December 2024, the Regulation on the Prohibition of Products Manufactured Using Forced Labour on the Union Market (Regulation (EU) 2024/ 3015, the so-called EU Forced Labour Regulation) entered into force. After 14 December 2027, it will prohibit products made through forced labour on the EU internal market. After that date, products made with forced labour may no longer be placed or made available on the Union market or exported. This applies both to products from the EU and from third countries.

Under the Regulation, the European Commission and the member states’ authorities must provide evidence that a product was made using forced labour. They have to conduct investigations into companies for this purpose. They should use a risk-based approach, prioritising serious cases and focusing on products, industries and companies with a particularly high risk of forced labour. State-imposed forced labour will also be a focus of the investigations. Starting on 14 December 2027, suspected cases of forced labour can be reported via a central EU portal for the Forced Labour Regulation.

Who is responsible for which investigation?

For risks outside the EU, the Commission will lead the investigations; for risks within the territory of an EU member state, the competent authority of that member state will take charge. If, while assessing the likelihood of violations of the Regulation, a public authority finds new information about suspected forced labour in another EU member state, it must notify the competent authority of that member state. If there are suspicions of forced labour outside the EU, it has to inform the Commission.

The public authority that conducted the investigation decides on whether a product made with forced labour should be prohibited, withdrawn from the market, or disposed of. If this decision is made by an authority of an EU member state, it then applies in all other EU member states according to the principle of mutual recognition.

In order to implement the Regulation in Germany, a so-called accompanying law is necessary. It specifies, among other things, the public authority responsible for investigations in Germany and its powers. The German Federal Government will prepare a corresponding draft law. The responsibilities of the respective authorities in Germany are currently being discussed in the Federal Government.

Critical products and components

Products of strategic or critical importance to the European Union that have been manufactured using forced labour constitute a special case. To avoid disruptions in the affected supply chains, these products do not necessarily have to be disposed of or destroyed. Instead, the competent authority may instruct the economic operator to withhold the product until it can demonstrate that forced labour has been eliminated.

Moreover, a destruction of entire products is not necessary if (only) exchangeable components were made using forced labour. In these cases, only the part affected by forced labour must be disposed of.

Support for companies

To support companies, the EU Forced Labour Regulation provides for a number of measures:

• Guidelines on the implementation of the regulation have already been published on the central EU portal. These are aimed especially at small and medium-sized enterprises (SMEs). The guidelines also highlight procedures which have proven to be useful for ending or eliminating various kinds of forced labour.
• On the portal, the European Commission also provides a checklist specifically designed for SMEs to help prevent forced labour violations, as well as an overview of freely available tools for tracking supply chains. Furthermore, it refers users to support services offered by the OECD and the International Labour Organisation (ILO).
• On its central portal, the European Commission will also set up a database containing verifiable and regularly updated information on the risks of forced labour, which will also include reports from international organisations (such as the International Labour Organisation).
• Specifically to support SMEs, member states are to establish contact points that can advise SMEs on issues related to the implementation of the EU Forced Labour Regulation and also offer assistance with correspondence with the European Commission and the competent authorities of the Member States during preliminary investigations and investigation procedures. The Federal Government is currently preparing the establishment of such an SME contact point.

Online seminars to prepare for the introduction of the EU Forced Labour Regulation

In preparation of the introduction of the EU Forced Labour Regulation, the European Commission will offer a number of virtual seminars from 14 September to 24 November 2026, focusing not only on SMEs but also, in particular, on various economic sectors. An overview of the events can be found on the website of the European Commission.

To complement the European Commission’s service, the Business and Human Rights Helpdesk, in cooperation with the Federal Ministry for Economic Affairs and Energy, will offer a three-part online seminar series in the autumn of 2026 (“The EU Forced Labour Regulation in Practice”), which will provide a practical overview of the regulation’s requirements and support services available to affected companies. The following online seminars are planned:

• 22 October 2026, 10:00 a.m. - 11.30 a.m.: 1. Online seminar: EUFLR in der Praxis - Orientierung durch Leitlinien (EUFLR in practice - guidelines for orientation) 
• 5 November 2026, 10:00 a.m. - 11.30 a.m.: 2. Online seminar: EUFLR in der Praxis - Klarheit für KMU (EUFLR in practice - clarity for SMEs)
• 2 December 2026, 10:00 a.m. - 11.30 a.m.: 3. Online seminar: EUFLR in der Praxis - EU-Datenbank für Zwangsarbeitsrisiken (EUFLR in practice - EU database for risks of forced labour)