As of December 14, 2027, placing, making available, or exporting products made using forced labor will be prohibited on the EU market. For businesses, understanding the new Regulation and strengthening their due diligence processes in light of it is a priority.
According to ILO estimates, over 27.6 million people worldwide are in situations of forced labor. This risk is particularly prevalent in supply chains, where corporate oversight is more complex.
Forced labor constitutes a serious violation of fundamental principles and rights at work, as defined by the 1998 ILO Declaration. The new Regulation (EU) 2024/3015 places this issue at the heart of European trade policy, introducing a ban applicable to all products, regardless of their origin, sector, or type.
What the Regulation entails
The Regulation is based on the definition of forced labour contained in the 1930 ILO Convention (No. 29), which describes it as any work or service exacted from a person under the menace of any penalty and for which the person has not offered themselves voluntarily.
The ban applies to products made “in whole or in part” using forced labour at any stage of their extraction, harvesting, production, or manufacture—including processing or transformation—and at any point in the supply chain, whether inside or outside the EU. Consequently, the Regulation does not merely address activities within operations directly controlled by the company; it requires particular attention to risks present throughout the entire value chain.
Once the Regulation becomes fully applicable, competent authorities will be able to launch investigations should evidence emerge of products made using forced labour. If a violation is confirmed, the measures provided for in the Regulation may be adopted, including a ban on placing such products on the EU market or making them available there.
Due diligence as a key process
A particularly relevant aspect for companies is the relationship between the Regulation and their own human rights due diligence processes.
The Forced Labour Regulation does not introduce additional due diligence obligations beyond those already established by applicable European legislation. However, it recognizes due diligence as a fundamental tool to help companies identify, prevent, mitigate, and address forced labor risks, and it stipulates that the Commission provide guidance to businesses on how to use it for this purpose.
The Guidelines on the Regulation, published by the Commission, suggest that companies integrate forced labor risks into their existing risk management processes and systems, rather than necessarily creating a separate system.
In particular, businesses are advised to:
- identify and assess forced labor risks within their own operations and along their value chains, focusing their analysis on the highest-risk areas, products, and business relationships;
- adopt a risk-based approach, prioritizing the most severe and most likely impacts;
- define clear responsibilities and governance mechanisms, and communicate expectations and requirements to suppliers and business partners;
- prioritize risk prevention and, where necessary, implement mitigation measures and corrective action plans;
- monitor the effectiveness of the measures taken over time and improve them based on the results;
- establish accessible grievance and reporting mechanisms.
Preparing for 2027
The Regulation introduces a significant shift: forced labor is becoming not only a human rights issue but also a risk factor for accessing the European market.
The process of preparing for the Regulation is already underway for companies, competent authorities, and civil society organizations: on June 30, 2026, the Commission published a package of tools and guidelines to support implementation and launched the Forced Labour Single Portal, the platform dedicated to its enforcement.
For companies, it is therefore crucial to turn the period leading up to the Regulation’s application into an opportunity to deepen their understanding of their value chains, integrate forced labor risks into existing due diligence systems, and establish processes capable of demonstrating how such risks are identified and managed.