The EU Forced Labour Regulation

With the EU Forced Labour Regulation (FLR) quickly 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.

*Based on 2022 Global Slavery Estimates from ILO 2022 

With enforcement starting on 14 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 focus for companies should therefore be on strengthening supply chain visibility and ensuring due diligence processes are robust enough to proactively prevent forced labor and withstand potential investigations. Companies that invest in meaningful due diligence are best positioned to avoid complicity and secure continued EU market access.

The FLR applies across all sectors, geographies, and company sizes, regardless of where risks occur in the supply chain, unlike other emerging due diligence regulations, such as the Corporate Sustainability Due Diligence Directive (CSDDD), that limit the scope of obligations to large companies. This means any company placing or making available 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 complements existing due diligence frameworks and aligns closely with international standards, specifically the UN Guiding Principles on Business and Human Rights and the OECD Guidelines, as well as broader ESG developments expecting transparent supply chains. Rather than imposing new due diligence obligations, the FLR builds on these foundations, allowing companies to leverage existing processes and investments.

Companies already applying these frameworks or preparing for emerging due diligence legislation such as the CSDDD, already have a solid foundation and are best positioned to meet FLR compliance. The FLR increases the pressure for companies to have transparent supply chains, and with enforcement coming up fast, companies anticipating these requirements will be best positioned to ensure market access.  

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, while also strengthening the foundations for long-term, sustainable value creation.

Preparing for the FLR should build on existing supply chain due diligence efforts, including CSDDD readiness. We help companies in assessing their current state and strengthening it into a robust, future-ready due diligence framework, leveraging and refining existing processes to meet rising regulatory expectations. We also support companies in navigating an increasingly complex global regulatory landscape, where overlapping and sometimes conflicting requirements, such as the tensions between PRC supply chain regulations and EU sustainability and due diligence obligations, require careful calibration to safeguard market access across jurisdictions.