This also includes (forced) child labor. The regulation entered into force on December 13, 2024, with most provisions becoming fully applicable on December 14, 2027.
What does this mean for your organization?
The FLR applies to all companies, across all sectors, and for all products, regardless of their origin. Products sold through e-commerce are also covered, while services are excluded.
The regulation follows the International Labour Organization (ILO) definition of forced labor: “All work or service which is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.”
The goals of the regulation are clear:
- Protect human rights.
- Prevent unfair competition.
- Encourage companies to apply due diligence throughout their supply chains.
How does the regulation work in practice?
Implementation of the FLR takes place in three stages:
- Detection
When forced labor is suspected, the country or region involved appoints a competent authority. Within the EU, national authorities are responsible for investigations; outside the EU, this role lies with the European Commission. - Investigation
Authorities conduct a risk-based investigation, considering factors such as:- the severity of the suspected forced labor
- the volume of products involved
- the degree of company involvement in the supply chain, and
- the level of influence companies can exert to stop forced labor.
- Decision
If forced labor is confirmed, the related products must be withdrawn from the market. Thanks to mutual recognition among EU Member States, a decision by one authority applies across the entire EU.
Prepare now: due diligence is key
The EU encourages companies to start implementing due diligence now, following the OECD Guidelines for Responsible Business Conduct. This means mapping your supply chains, identifying risks, and taking proactive steps to prevent forced labor.
Arecent report by the Dutch Ministry of Foreign Affairs identified 44 countries with a high risk of forced labor. Industries such as textiles, agriculture, and steel are particularly vulnerable.
What can you do today?
Map your suppliers. Assess risks. Strengthen your processes.
Not sure where to start? We’re here to help. Together, we’ll explore how your organization can prepare effectively for these upcoming obligations.
Contact us to learn more or to discuss how we can support you. ⬇️
Steven Sewberath Misser
Sr. Customs Specialist