Are you ready for the EU Forced Labour Regulation?

The EU’s Forced Labour Regulation (EU) 2024/3015 (the "FLR") represents one of the most significant recent developments in supply chain governance. It establishes a comprehensive framework to prohibit the placing, making available and export of products made with forced labour on the EU market. With enforcement provisions set to apply from 14 December 2027, businesses operating in or supplying into the EU should be preparing now.

What does the FLR do?

The FLR prohibits economic operators from placing on the EU market, or exporting from it, any product that has been made with forced labour at any stage of its production, manufacture, harvest or extraction.

The FLR is product-focused rather than entity-focused. It applies regardless of the size of the company and irrespective of whether the forced labour occurred within or outside the EU. This broad scope means that all economic operators – including manufacturers, importers, distributors and exporters – must exercise heightened vigilance over their supply chains.

How will the FLR be enforced?

Enforcement of the FLR will be carried out by designated competent authorities in each EU Member State, supported by the Commission and a newly established Forced Labour Single Portal available to the public. On the Forced Labour Single Portal, in addition to information on competent authorities, FLR guidelines and decisions to ban products (among others), there will be a single information submission point where information on alleged violations of the FLR can be submitted.

The enforcement framework is risk-based – using certain criteria including the scale and severity of the suspected forced labour – and operates in two phases.

• In the preliminary phase, the competent authority must request information about what the economic operator has done to identify, prevent, mitigate bring to an end or remediate risks of forced labour in its operations and supply chains with respect to the products under assessment.
• Where there is a “substantiated concern” of an FLR violation, the competent authority can initiate a formal investigation. A substantiated concern means a reasonable indication based on objective, factual and verifiable information for the Commission or competent authorities to suspect that it is likely that a product was made with forced labour. Where an FLR violation is established, the competent authority will reach a decision on prohibiting the placing or making available of the products on, or withdrawing them from, the EU market or disposing of them. Such decisions will be recognised and enforced across all EU Member States.

Competent authorities must impose penalties on entities who fail to comply with a decision. Member States are also able to set penalties that are effective, proportionate and dissuasive and give regard to certain factors including the gravity and duration of the infringement.

At the end of April (effective 17 May 2026), the Commission released its Implementing Regulation (EU) 2026/903 outlining the information and communication system that will support enforcement of the FLR. It creates a “forced labour module” within the existing Information and Communication System for Market Surveillance (ICSMS) to facilitate and standardise information exchange between the Commission, Member State competent authorities and relevant customs authorities when investigating, deciding and enforcing. The system will enable coordination of investigations across Member States, including requests for mutual assistance and support between competent authorities. Businesses can therefore expect a systematic and cross-border approach to investigations and enforcement actions.

How can you prepare for the FLR?

While the FLR does not impose a standalone due diligence obligation like the Corporate Sustainability Due Diligence Directive (CSDDD), companies that have conducted meaningful due diligence on forced labour risks in their supply chains will significantly reduce the risk of supply chain interruptions and be better placed to respond to any investigation. In practice, businesses should consider the following preparatory steps:

Supply chain mapping and risk assessment

Understanding where your products are sourced and manufactured is essential. Businesses should map their supply chains to the greatest extent possible (i.e., beyond tier 1) and assess forced labour risk by reference to sector, geography and the nature of the workforce involved.

Review of existing due diligence procedures

Businesses that are already subject to due diligence obligations – whether under the CSDDD or comparable national legislation – should review and, where necessary, enhance their policies and processes to ensure that forced labour risks are adequately addressed. For those not currently subject to such requirements, the FLR provides a strong impetus to develop and implement proportionate due diligence measures.

Contractual protections and supplier engagement

Businesses should review their supplier contracts to ensure that appropriate representations, warranties and audit rights relating to forced labour are in place. Proactive engagement with suppliers will be important in demonstrating good faith efforts to identify and mitigate forced labour risks.

Internal governance and training

Establishing clear internal policies and governance structures for managing forced labour risk and ensuring that relevant personnel are trained to identify and escalate concerns, will be critical to demonstrating organisational readiness.

Looking ahead

The FLR forms part of a broader shift in the EU's regulatory landscape towards accountability for harms to people and the environment in corporate supply chains. Taken together with the CSDDD and the EU Deforestation Regulation (EUDR), among others, the direction of travel is clear: businesses are expected to take meaningful, verifiable steps to identify, prevent, mitigate and address such harms or risk regulatory sanctions, operational disruption and reputational damage.

With the FLR’s application date approaching, businesses should not delay in assessing their exposure and developing a robust compliance roadmap. Early movers will reduce the risk of enforcement action, product withdrawal and reputational harm, in addition to positioning themselves favourably in an increasingly conscientious marketplace.

For more on the FLR, see our prior briefing here. For further guidance and tailored advice on the FLR or anything else discussed in this briefing, please get in touch with Kerry Stares or with your usual Charles Russell Speechlys contact.