Forced labour ban and supply chain due diligence

• Regulation (EU) 2024/3015 on prohibiting products made with forced labour
• Directive (EU) 2024/1760 — corporate sustainability due diligence
• Regulation (EU) 2017/821 — conflict minerals
• Regulation (EU) 2023/1115 — EUDR

Who has to appoint one

Companies placing goods on the EU market whose supply chains reach high-risk regions or sectors. The forced labour Regulation applies to all products regardless of company size and prohibits placing on the market products made with forced labour anywhere in the chain.

Thresholds and exemptions

The forced labour prohibition has no size threshold. The due diligence Directive applies above defined employee and turnover thresholds, phasing in from 2027. Conflict minerals rules apply to importers above volume thresholds.

What must appear on the label

No label. What is required is documentation of the supply chain and the ability to demonstrate the origin of inputs on request.

Marketplace fields

Buyers cascade the requirements contractually, so suppliers below the legal thresholds face them commercially. Public procurement increasingly excludes suppliers unable to evidence due diligence.

Documentation you must hold

Supply chain mapping to the level required by each instrument, risk assessment and mitigation records, supplier codes of conduct with audit rights, grievance mechanisms, and for EUDR the due diligence statement with geolocation. For conflict minerals, the chain of custody and third-party audit.

Standards and testing

Not product testing but supply chain verification: audits, worker interviews and, increasingly, isotope or DNA testing to verify claimed origin of cotton and other commodities.

Language requirements

Documentation in a language accessible to the authorities requesting it, and grievance mechanisms in the language of the workers concerned.

When it applies

The forced labour Regulation applies from 14 December 2027. The due diligence Directive phases in from 2027 by company size. EUDR from December 2025 and June 2026 by operator size.

How long records are kept

Five years for EUDR records, and per instrument for the others.

What happens if you do not comply

Under the forced labour Regulation, an order to withdraw and dispose of the products, at the operator's cost, with no fine ceiling because the remedy is removal from the market. Under the due diligence Directive, penalties based on turnover and civil liability for harm.

Who enforces it

National competent authorities designated for each instrument, customs, and the Commission for cases involving third-country risk areas.

Where the boundary lies

These instruments are cumulative rather than alternative, and a single consignment of cotton garments can engage the forced labour prohibition, the deforestation Regulation for viscose components and the due diligence Directive at once. Being below a size threshold does not help when your customer is above it.

Questions we are asked

Does the forced labour Regulation apply to small companies?

Yes. The prohibition applies to products regardless of the size of the operator, though enforcement is expected to be risk-based.

Is an audit enough?

Audits are evidence, not compliance. Authorities look at the risk assessment, the actions taken and the outcomes, and a clean audit from a discredited scheme carries little weight.