Forced labour regulation EU: what it bans, from when, and what to do

The Forced Labour Regulation is Regulation (EU) 2024/3015Regulation (EU) 2024/3015, Forced Labour RegulationThe whole regulationClick opens the law on the EU Publications Office.. It bans products made with forced labour from the EU market, whoever sells them and wherever they were made. It does not ask a business to file or certify anything. It lets the Commission and national authorities investigate a product, ban it by decision, and have it pulled from sale and disposed of (Art. 3Regulation (EU) 2024/3015, Forced Labour RegulationArticle 3Click opens the article on EUR-Lex., Art. 1(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 1, paragraph 3Click opens the article on EUR-Lex., Art. 20(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.). It applies from 14 December 2027 (Art. 39Regulation (EU) 2024/3015, Forced Labour RegulationArticle 39Click opens the article on EUR-Lex.).

Who the ban applies to

The ban is on conduct, not on a class of business. “Economic operator” means any natural or legal person, or association of persons, that places products on the EU market, makes them available on it or exports them (Art. 2(9)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 9Click opens the article on EUR-Lex.). “Placing on the market” is the first making available of a product on the EU market, and “making available” is any supply for distribution, consumption or use in the course of a commercial activity, paid or free (Art. 2(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 4Click opens the article on EUR-Lex., Art. 2(5)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 5Click opens the article on EUR-Lex.). So the ban reaches the manufacturer, the importer, the wholesaler and the shop alike. The Regulation sets no size threshold. The Commission’s guidelines read it as covering distributors inside the EU too, and say the ban is “unconditional and absolute”. That is guidance, not law.

A “product” is any item that can be valued in money and can be the subject of commercial transactions, whether extracted, harvested, produced or manufactured (Art. 2(6)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 6Click opens the article on EUR-Lex.). That takes in raw materials and farm produce as well as manufactured goods. Services are not products. The guidelines say transport, warehousing and logistics are outside the Regulation even when linked to placing the product on the market (recital 18; guidelines section 3.1).

An importer, in the Regulation’s own words, is a person established in the EU who places a product from a third country on the EU market (Art. 2(14)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 14Click opens the article on EUR-Lex.). Who that is for a given shipment is the question the importer of record page answers.

The Regulation binds the 27 EU countries today. The Commission’s guidelines say they also apply to Norway, Iceland and Liechtenstein once the EEA Agreement includes the Regulation, and to Northern Ireland once the Regulation is added to the Windsor Framework. For Northern Ireland, the Council adopted the EU position on 29 September 2025: the Regulation, except Article 36, is to be added to Annex 2 of the Windsor Framework by decision of the Joint Committee (Council Decision (EU) 2025/2047). We found no Joint Committee decision adding it on 5 October 2026. For the three EEA countries, we found no EEA Joint Committee decision incorporating it on 5 October 2026, and on 3 October 2026 the EFTA secretariat listed it as under scrutiny for incorporation. A seller outside all of these, in Great Britain for example, is still bound when it makes products available to buyers in the EU (Art. 4Regulation (EU) 2024/3015, Forced Labour RegulationArticle 4Click opens the article on EUR-Lex.).

What counts as a product made with forced labour

“Forced labour” is forced or compulsory labour as defined in Article 2 of ILO Convention No 29, including forced child labour (Art. 2(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 1Click opens the article on EUR-Lex.). That is work or service exacted from a person under the menace of a penalty, which the person has not offered to do voluntarily. Forced labour imposed by state authorities is the use of forced labour described in Article 1 of ILO Convention No 105 (Art. 2(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 2Click opens the article on EUR-Lex.).

A product is “made with forced labour” if forced labour was used in whole or in part at any stage of its extraction, harvest, production or manufacture, including in the working or processing of it at any stage of its supply chain (Art. 2(7)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 7Click opens the article on EUR-Lex., Art. 2(8)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 8Click opens the article on EUR-Lex.). Two things follow. A product is caught when only a part or a component was made with forced labour. And it does not matter whether the forced labour was in your own site or in a supplier’s. The guidelines add that the size of the share does not decide whether the product is in scope. It affects how an authority prioritises cases and the time it gives you to comply (Art. 14(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 2Click opens the article on EUR-Lex., point (c); Art. 22(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex., point (b); guidelines section 3.1).

How it reaches online sales and sellers outside the EU

A product offered for sale online or by other distance sales is deemed made available on the EU market if the offer is targeted at end users in the EU. An offer is targeted if the business directs its activities, by any means, to an EU country (Art. 4Regulation (EU) 2024/3015, Forced Labour RegulationArticle 4Click opens the article on EUR-Lex.). Recital 22 names the factors for a case-by-case look: the areas it can dispatch to, the languages used for the offer or the order, the means of payment, an EU country currency, a domain name registered in an EU country. It adds that an interface that merely can be opened from an EU country is not enough. The same recital says the authorities can act on such a product even though it has not yet been placed on the market, and that it must comply when it is actually placed on the market, which for an import means release for free circulation (Art. 2(19)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 19Click opens the article on EUR-Lex., Art. 2(21)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 21Click opens the article on EUR-Lex.).

A marketplace is not exempt, and it is not the only one in the chain. Recital 23 says information related to the sale of a product that violates the ban is illegal content within the meaning of Article 3, point (h), of the Digital Services Act, so the marketplace’s duties under that Act apply. A decision can order the business that was investigated to remove content from an online interface that refers to the products (Art. 20(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex., point (b)), and the authorities can ask the third party that hosts the listing to restrict access to it (Art. 23(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 23, paragraph 1Click opens the article on EUR-Lex., point (d)). What a marketplace asks of its sellers under that Act is on the Digital Services Act trader checks page.

When it applies, and what has been published since 2024

The date has not moved. On 5 October 2026 the Commission’s portal and its guidelines both state 14 December 2027, and no act amending the Regulation or postponing its date turned up in our check. The one amendment the Regulation itself makes is to the whistleblower Directive (Art. 36Regulation (EU) 2024/3015, Forced Labour RegulationArticle 36Click opens the article on EUR-Lex.).

What exists today, with its date:

• The guidelines. Commission Notice C/2026/4637, adopted as C(2026) 4386 on 26 June 2026, twelve days after the Regulation’s deadline, and published in the Official Journal on 3 September 2026. They cover the investigation, enforcement and penalties, and voluntary due diligence in relation to forced labour, with parts aimed at small and medium-sized businesses. Only the Regulation has legal force; the guidelines say so themselves.
• The Forced Labour Single Portal. Opened on 30 June 2026. It holds the guidelines, the database page, a checklist for small and medium-sized businesses and a link to the list of national authorities (Art. 12Regulation (EU) 2024/3015, Forced Labour RegulationArticle 12Click opens the article on EUR-Lex.).
• The risk database. The Commission’s page for it exists and describes what the database will hold and how it is meant to be used. On 5 October 2026 it still carries the label “Database in development”. The Regulation set 14 June 2026 for it (Art. 8(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 8, paragraph 3Click opens the article on EUR-Lex.).
• The information system. Implementing Regulation (EU) 2026/903 of 24 April 2026 created the forced labour module of the market surveillance system, the tool the authorities use to share investigations and decisions with each other and with customs. It entered into force on the twentieth day after its publication on 27 April 2026 (Art. 1(1), Art. 11).
• The single information submission point. Anyone can report a suspected case through it. It is not open yet: the Commission’s page gives 14 December 2027.

What does not exist yet, as far as we could find on 5 October 2026: a delegated act naming the product groups for which customs will want extra information on the declaration (Art. 27(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 27, paragraph 1Click opens the article on EUR-Lex.), and a second implementing act for the automated link between the information system and customs (Art. 7(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 7, paragraph 3Click opens the article on EUR-Lex., Art. 7(7)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 7, paragraph 7Click opens the article on EUR-Lex.).

How an investigation runs

The Commission and national authorities follow a risk-based approach. They prioritise by the scale and severity of the suspected forced labour, the quantity of products on the EU market and the share of the part made with forced labour in the final product (Art. 14(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 1Click opens the article on EUR-Lex., Art. 14(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 2Click opens the article on EUR-Lex.). They draw on the database, the risk indicators, submissions through the single information submission point and information from other authorities (Art. 14(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 3Click opens the article on EUR-Lex.). They focus, as far as possible, on the businesses closest to where the forced labour is likely happening and with the most leverage over it, and take into account size and economic resources, in particular whether the business is an SME (Art. 14(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 4Click opens the article on EUR-Lex.). The guidelines add that for forced labour outside the EU, importers are likely to be key businesses for the authorities (section 4.3.2).

Who leads depends on where the suspected forced labour is. Outside the EU, the Commission leads. Inside an EU country, that EU country’s authority leads (Art. 15Regulation (EU) 2024/3015, Forced Labour RegulationArticle 15Click opens the article on EUR-Lex.).

A “substantiated concern” is a reasonable indication, based on objective, factual and verifiable information, that it is likely the product was made with forced labour (Art. 2(16)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 16Click opens the article on EUR-Lex.). The business has the right to be heard at every stage (Art. 16(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 16, paragraph 2Click opens the article on EUR-Lex.). The burden of establishing that forced labour was used lies with the authority, not with the business; that is recital 47 and the guidelines (section 4.8.1), not an article.

The Regulation gives the standard of evidence to the Commission’s guidelines (Art. 11Regulation (EU) 2024/3015, Forced Labour RegulationArticle 11Click opens the article on EUR-Lex., point (c)). They say the authority must provide credible evidence, on an administrative, not a criminal, threshold. They list examples, among them social audits, interview transcripts, satellite imagery and traceability records, and say audits done under surveillance are not credible. They also say that a complete lack of traceability information, or an inability to provide it, may weigh against the business (section 4.8.1.1). That is guidance, not law.

Two cases speed things up. The authority can skip the request for information in the preliminary phase if asking would jeopardise the outcome (Art. 17(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 17, paragraph 1Click opens the article on EUR-Lex.). And if a business or a public authority refuses to give the information, is late, gives incomplete or incorrect information to block the case, misleads, or otherwise impedes the investigation, the authority may find a violation on any other facts available (Art. 20(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 2Click opens the article on EUR-Lex.).

What happens to a banned product

If the authority establishes a violation, it decides without delay. The decision contains three things (Art. 20(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex.):

• a prohibition on placing or making available the products on the EU market and on exporting them;
• an order to withdraw the products already placed or made available, or to remove content from an online interface that refers to them or lists them;
• an order to dispose of them under Article 25Regulation (EU) 2024/3015, Forced Labour RegulationArticle 25Click opens the article on EUR-Lex., or, where the part that violates the ban can be replaced, to dispose of that part. The decision then says which part must be replaced for the product to be sold again.

The time to comply is set in the decision. It is at least 30 working days, and at least 10 working days for perishable goods, animals and plants, and it must take into account the business’s size and resources, including whether it is an SME, and whether the part is replaceable (Art. 22(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex., point (b)). The decision also states the findings, how the product is identified, and how to take it to court (Art. 22(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 22, paragraph 1Click opens the article on EUR-Lex.).

How disposal works. Following the waste hierarchy, a banned product is recycled or, if that is not possible, rendered inoperable. Perishable goods are donated for charitable or public interest purposes or, if that is not possible, rendered inoperable (Art. 25Regulation (EU) 2024/3015, Forced Labour RegulationArticle 25Click opens the article on EUR-Lex.). The cost is the business’s: if it does not comply, the authorities carry out the disposal at its expense (Art. 23(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 23, paragraph 1Click opens the article on EUR-Lex., point (c)).

Withholding instead of disposal. For a supply chain of strategic or critical importance to the EU, the authority may order the product withheld for a defined period at the business’s cost instead of disposed of. If the business shows within that period that it ended the forced labour without changing the product, the decision is reviewed. If not, disposal follows (Art. 20(5)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 5Click opens the article on EUR-Lex.).

Who is bound. The decision names the businesses that were investigated. Decisions of one EU country’s authority are recognised and enforced by the authorities of the others for products with the same identification information from the same supply chain (Art. 20(8)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 8Click opens the article on EUR-Lex.). The guidelines read the prohibition as applying to every business that places or makes the product available, not only to the ones named (section 4.8.3). That is the Commission’s reading; the text of Article 20(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 4Click opens the article on EUR-Lex., point (a), prohibits placing and making available “the products concerned”.

Getting a ban lifted. A business can ask for a review at any time, with new substantial information that was not before the authority. The authority decides within 30 working days. Once the business has shown it complied and eliminated forced labour from its operations or supply chain for those products, the authority withdraws the decision for the future and removes it from the portal (Art. 21(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 21, paragraph 1Click opens the article on EUR-Lex., Art. 21(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 21, paragraph 2Click opens the article on EUR-Lex., Art. 21(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 21, paragraph 3Click opens the article on EUR-Lex.). A decision of a national authority can be taken to a court. A Commission decision is an implementing act (Art. 21(5)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 21, paragraph 5Click opens the article on EUR-Lex., Art. 20(6)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 20, paragraph 6Click opens the article on EUR-Lex.). The guidelines say a Commission decision goes to the Court of Justice of the European Union, meaning the General Court and the Court of Justice. They also say a review can be requested by the businesses the decision is addressed to and by those that prove they are directly and individually affected (sections 4.9.1, 4.9.3). That is the Commission’s reading.

What happens at the border

The prohibition covers imports and exports. Customs authorities work from the decisions the lead authority sends them and control, on a risk basis, products entering or leaving the EU (Art. 26(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 26, paragraph 3Click opens the article on EUR-Lex., Art. 26(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 26, paragraph 4Click opens the article on EUR-Lex.). The Regulation applies to the customs procedures “release for free circulation” and “export” (Art. 2(19)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 19Click opens the article on EUR-Lex., Art. 2(20)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 2, point 20Click opens the article on EUR-Lex.). Forced labour leaves no trace on the product (recital 55), so customs cannot see it. They look for a match with a decision.

1. Suspension. If a product might be covered by a decision, customs suspend its release for free circulation or export, and tell the national authority at once (Art. 28Regulation (EU) 2024/3015, Forced Labour RegulationArticle 28Click opens the article on EUR-Lex.).
2. Four working days. If the authority has not asked customs to keep the suspension within 4 working days (2 for perishable goods, animals and plants), the product is released, if all other requirements are met. Release is not proof of compliance (Art. 29(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 29, paragraph 1Click opens the article on EUR-Lex., Art. 29(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 29, paragraph 2Click opens the article on EUR-Lex.).
3. Refusal. If the authority concludes that the product is covered by a decision, customs do not release it or allow its export, and put a notice in their data system and, where possible, on the commercial invoice: “Product made with forced labour – release for free circulation/export not authorised – Regulation (EU) 2024/3015Regulation (EU) 2024/3015, Forced Labour RegulationThe whole regulationClick opens the law on the EU Publications Office.” (Art. 30(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 30, paragraph 1Click opens the article on EUR-Lex., Art. 30(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 30, paragraph 2Click opens the article on EUR-Lex.).
4. Disposal. Customs dispose of the refused product under national law, or, if the authority asks, seize it for the authority to dispose of it under Article 25 (Art. 30(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 30, paragraph 3Click opens the article on EUR-Lex., Art. 30(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 30, paragraph 4Click opens the article on EUR-Lex.). The guidelines say no re-export or modification is possible and that the business bears the cost (section 5.1.6).

To help customs find matches, the Commission may, by delegated act, name product groups for which the person lodging the declaration must give customs information on the product, its manufacturer or producer and its product suppliers, unless customs law already requires it (Art. 27(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 27, paragraph 1Click opens the article on EUR-Lex., Art. 27(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 27, paragraph 2Click opens the article on EUR-Lex.). None had been named when we checked.

What the penalty is for

The ban itself carries no fine. EU countries must lay down penalties for non-compliance with a decision, and they must be effective, proportionate and dissuasive (Art. 37(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 37, paragraph 1Click opens the article on EUR-Lex., Art. 37(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 37, paragraph 2Click opens the article on EUR-Lex.). They give due regard to the gravity and duration of the non-compliance, earlier non-compliance, the degree of cooperation, and any gain or loss avoided. EU countries notify the Commission of their rules by 14 December 2026 (Art. 37(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 37, paragraph 3Click opens the article on EUR-Lex.) and must take utmost account of the Commission’s guidance on how to calculate fines (Art. 37(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 37, paragraph 4Click opens the article on EUR-Lex.). The guidelines say the Regulation sets no minimum or maximum amount, so each country decides, and that penalties follow placing the banned product on the market, failing to withdraw or dispose of it, failing to replace the part, or failing to withhold it (section 5.2).

No country has published its penalty rules that we could find. The national amounts are therefore unknown today.

What you can set aside

What the law leaves open

• Which business the authorities look at first. The Regulation says the authorities focus on the businesses closest to the forced labour with the most leverage (Art. 14(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 14, paragraph 4Click opens the article on EUR-Lex.). For forced labour outside the EU that business may have no link to the EU, and the guidelines say importers are then likely to be the key businesses. Nothing in the text says how an online seller shipping straight to consumers will be ranked.
• What the national penalties are. Not published yet. The Regulation sets the factors, not the amounts (Art. 37Regulation (EU) 2024/3015, Forced Labour RegulationArticle 37Click opens the article on EUR-Lex.).
• When the risk database is complete. The Regulation required it by 14 June 2026 (Art. 8(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 8, paragraph 3Click opens the article on EUR-Lex.). The Commission’s page for it says “Database in development”. Until it is complete, the sectors and areas it names are not final.
• When customs get the automated link. The Regulation gives two years from a second implementing act for the automated link between the information system and customs, and four years from the first implementing act for the link with the EU Single Window Environment for Customs (Art. 7(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 7, paragraph 3Click opens the article on EUR-Lex., Art. 7(5)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 7, paragraph 5Click opens the article on EUR-Lex.). The first act is Implementing Regulation (EU) 2026/903, adopted on 24 April 2026. We found no second one. Customs must still act on the decisions they receive (Art. 26(4)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 26, paragraph 4Click opens the article on EUR-Lex.).

Meanwhile, keep for each product the producer’s name, address and country, the production site and the parts that come from other producers. That is what an authority asks for once an investigation opens (Art. 18(3)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 18, paragraph 3Click opens the article on EUR-Lex.). The first request asks what you did about forced labour risks (Art. 17(1)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 17, paragraph 1Click opens the article on EUR-Lex.). A customs declaration may need the same information for the first product group the Commission names (Art. 27(2)Regulation (EU) 2024/3015, Forced Labour RegulationArticle 27, paragraph 2Click opens the article on EUR-Lex.).