What changed

The Forced Labour Regulation, (EU) 2024/3015, applies from 14 December 2027. The Commission published its guidelines in June 2026.

  • No thresholds. There is no size threshold, no sector exemption and no minimum value. A single component is enough.
  • No grandfathering. Stock already in your supply chain on 14 December 2027 is covered.
  • A low bar for evidence. Authorities can use satellite imagery, trade data and NGO reports. If you can’t answer their questions, that can count against you.
  • Withdrawal and disposal. A banned product must be withdrawn and, in principle, disposed of at your expense. You get at least 30 working days to comply.
  • Due diligence is not a safe harbour. It is still what you’ll be asked to show: supply chain maps, bills of materials and customs records.

What it puts at risk

Revenue

A ban stops sales of the product across the EU, and exports from it too. If the tainted input is a component, the finished product is caught. UK firms selling into the EU are exposed as well.

Cost

You pay for withdrawal and disposal. Replacement suppliers usually cost more to qualify and to buy from.

Cash

Stock bought today could be unsellable in 2028. Extra buffer stock and dual sourcing tie up working capital.

Continuity

Thirty working days is about six weeks, which is rarely enough to qualify a new supplier. If you can’t name your tier 2 and tier 3 sources, you can’t answer an authority.

Our view

Most mid-sized companies treat this as a compliance file for 2027. We’d put it on the risk register now, next to supplier failure, because the outcome is the same: a product line that stops.

The exposure sits two or three tiers down, where few companies can see. Falling outside the CSDDD thresholds doesn’t take you out of this rule.

Start narrow. Find the few products where one input from a high-risk region would stop the line. For those, build the evidence pack and a Plan B supplier first.

This is our reading of the Regulation, not legal advice.

Three questions for the board

  1. Which of our EU products rely on an input from a region or sector flagged for forced labour risk?
  2. How long would it take us to produce the supply chain map and bill of materials for our top product line?
  3. For our three most exposed inputs, could a qualified alternative supplier take over within six weeks?

Sources

Regulation (EU) 2024/3015, on EUR-Lex

European Commission guidelines on the Forced Labour Regulation, June 2026

Photo: Trisha Downing on Unsplash.