Guide to the EU Forced Labour Regulation (EU-FLR)

The EU Forced Labour Regulation applies to all products sold in or exported from the EU market. The regulation will be fully enforced starting 14 December 2027.

The primary goal of the EU Forced Labour Regulation (EU-FLR) is to ensure that products produced wholly or partially with forced labour are neither sold in nor exported from the EU market. Under this regulation, authorities from Member States and the European Commission may investigate suspicious goods, supply chains, and manufacturers, taking a risk-based approach. If they determine that a product has been made with forced labour, it cannot be sold on the EU market (including online), and any such shipments will be stopped at the EU’s borders. This applies to all products and components, regardless of where they come from: inside or outside the EU.

In responding to an investigation, companies are required to provide evidence of due diligence proving their products are free from forced labour. Although the EU-FLR does not impose new due diligence obligations beyond those already set by Union or national laws, businesses must be able to provide documentation within 30 working days to authorities where an investigation is initiated.

How we can help

Our value chain experts at Forvis Mazars can support you with:

  • Navigating the complex interaction between legislative requirements on human rights and forced labour across multiple jurisdictions
  • Integrating human rights risks into your risk management system
  • Understanding how you can meaningfully integrate your due diligence and reporting obligations stemming from different ESG regulations
  • Conducting a value chain risk assessment to help you understand your exposure to forced labour risks and to prioritise risks based on severity and likelihood of occurrence
  • Setting up systems and processes to collect and update information that might be requested by authorities or your business partners
  • Drafting policies or supplier codes of conduct as well as setting up suitable governance structures
  • Establishing supplier engagement on forced labour risks
  • Set up indicators to measure effectiveness of due diligence process / tailored to forced labour
  • Providing training to your management, procurement department and suppliers
  • Setting up suitable documentation and providing guidance on what to prioritise

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Preparing for the EU Forced Labour Regulation: a practical guide

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