The EU Forced Labour Regulation

With the EU Forced Labour Regulation (FLR) approaching, companies face a clear shift: access to the EU market will depend on their ability to identify and address forced labour risks in their supply chains. Around 27 million people* worldwide are trapped in forced labour, highlighting the scale of the issue.

The FLR raises the stakes for global supply chains but also provides direction: companies that act early and invest in transparency will be better positioned to ensure compliance, market access, and business continuity.

With enforcement starting in December 2027, companies are expected to identify, prevent, and address risks across their supply chains. The FLR sets a clear rule: products linked to forced labour cannot be placed on or exported from the EU market. Acting now is essential to maintain market access.

The FLR applies across all sectors, geographies, and company sizes, regardless of where risks occur in the supply chain. This means any company placing products on the EU market must understand and manage its exposure: non-compliance can lead to immediate operational, financial, and market access consequences.

The FLR aligns with international standards and existing due diligence frameworks, allowing companies to build on current processes. At the same time, it increases the pressure for greater supply chain transparency.

The FLR will be enforced through a risk-based investigation model by national competent authorities. Agricultural products, critical minerals, and consumer and industrial goods are likely to be prioritised in upcoming EU guidance.

What happens when products are investigated?

If further investigation is required, the national authority may ask the company to demonstrate how it identifies, mitigates, and manages forced labour risks. Companies are typically required to respond within 30 working days.

Where investigations conclude that a product has been made in whole, or in part with forced labour:

• products will be prohibited from being placed on the EU market
• products already on the market will be withdrawn
• goods may be destroyed or otherwise withheld or, where deemed of critical importance to the EU, temporarily withheld while pending further decisions
• economic operators that fail to comply, particularly repeat offenders, may face financial penalties

Focus on three things: know your risks, see your supply chain, and be ready to act.

• Know where the real risks are
  Identify where forced labour is most likely, based on geography, sector, and labour models. Make sure vulnerable workers can raise concerns — this is often where hidden risks surface first.
• Prioritise visibility where it matters most
  Focus on high-risk products, suppliers, and upstream areas beyond Tier 1. You don’t need full transparency everywhere — but you do need it where exposure is highest.
• Be ready to respond
  Ensure you can evidence your due diligence, act on signals quickly, and escalate issues clearly. Regulators will not only look at risks — but at how you handle them.

We support companies in moving from insight to action — from understanding current risks to building a focused, investigation-ready approach that stands up to regulatory scrutiny.

Under the FLR, transparency is no longer a ‘nice to have’ — it becomes a condition for market access. Companies that focus early on the right risks and the right parts of their supply chain will be better positioned to stay in the EU market.