From 14 December 2027, Regulation (EU) 2024/3015, known as the EU Forced Labour Regulation (EUFLR), will apply. From that date, economic operators will be prohibited from placing or making available on the Union market, or exporting from the Union, products made with forced labour. The prohibition applies to products of any type, sector or origin and to economic operators of all sizes.
The EUFLR does not prescribe a single compliance model or create additional due diligence obligations beyond those already provided for under Union or national law. Economic operators must, however, be able to address forced labour risks in their supply chains and provide relevant information and evidence if requested by the competent authorities. In preparing for the Regulation, Trusty can support companies with solutions for managing, organising and tracing supply chain data.
What is meant by forced labour
The Regulation refers to the definition of forced or compulsory labour set out in Convention No. 29 of the International Labour Organization (ILO): work or service exacted from a person under the menace of a penalty and for which that person has not offered themselves voluntarily.
The Regulation also addresses forced labour imposed by state authorities and includes forced child labour within the definition of forced labour.
Risk indicators identified in the European Commission Guidelines include, for example, restrictions on workers’ movements, retention of identity documents, withholding of wages, threats or intimidation, exploitation of debt and abuse of vulnerability.
Forced labour may occur far upstream in a supply chain. A T-shirt sold in the EU, for example, may fall within the scope of the prohibition if the cotton used to make it was harvested using forced labour, even if the subsequent spinning, manufacturing and sale took place without the use of forced labour.
The Regulation covers forced labour used in whole or in part at any stage of a product’s extraction, harvest, production or manufacture, including the working or processing related to the product at any stage of its supply chain.
How investigations will work
The European Commission and Member States’ competent authorities will follow a risk-based approach when assessing and investigating possible violations. Where the suspected forced labour takes place outside the territory of the Union, the European Commission acts as the lead competent authority. Where it takes place within the territory of a Member State, a competent authority of that Member State acts as the lead competent authority.
During the preliminary phase of an investigation, the lead competent authority may request information from economic operators under assessment and, where relevant, from other product suppliers on the actions they have taken to identify, prevent, mitigate, bring to an end or remediate forced labour risks in their operations and supply chains. Economic operators must respond within 30 working days of receiving the request.
If the lead competent authority establishes that there is a substantiated concern that the prohibition may have been violated, it will initiate an investigation. During the investigation, the authority may request further information and must set a deadline of at least 30 and no more than 60 working days for economic operators to provide it.
The information requested may concern measures addressing forced labour risks, working conditions and, importantly, product traceability and supply chain structure. The Commission Guidelines provide examples including direct and indirect suppliers, production sites, the origin of raw materials, product or batch identification, supply chain maps and documentation linking the finished product to its raw-material source. This is also one of the key areas addressed in Trusty’s information note.
What happens if a violation is established
If the competent authority establishes a violation of the prohibition on products made with forced labour, it may prohibit their placing or making available on the Union market or their export, and order their withdrawal and disposal in accordance with the Regulation.
Penalties apply where an economic operator fails to comply with an authority’s decision, for example by continuing to make a prohibited product available on the market or by failing to withdraw it as required. Member States must provide for penalties that are effective, proportionate and dissuasive.
How to prepare for 14 December 2027
Companies can start preparing now through six practical steps:
- Map the supply chain, identifying suppliers, production sites, products, components and the origin of raw materials.
- Assess risks by country, sector, product and supplier, drawing on resources such as the Forced Labour Single Portal, the EU forced labour risk database and ILO sources.
- Formalise expectations through policies, codes of conduct and contractual clauses.
- Investigate higher-risk situations through checks, monitoring and corrective or remediation measures.
- Connect products, batches, origins and supporting documentation, avoiding information being scattered across separate files and systems.
- Prepare to respond to information requests, ensuring that relevant evidence can be retrieved quickly if requested by the competent authorities.
The European Commission has also made available an Anti Forced Labour Preparedness Checklist for SMEs, together with tools and resources designed to help businesses understand and assess forced labour risks across their supply chains.
Preparing for the EUFLR through supply chain data
For many companies, the first useful question is not yet “are we compliant?”, but rather “how well do we really know our supply chain, and how quickly could we document it?”
This is where Trusty can support companies in their preparation for the Regulation: starting from the data already available to map suppliers, origins, production sites, products and batches, identify information gaps, and organise evidence in a more structured and accessible way.
Better-organised information can also help simplify day-to-day operations. When data and documents are spread across different files, systems and business functions, reconstructing a supply chain can be time-consuming and involve repetitive work. Connecting information more consistently can reduce duplication, speed up the retrieval of evidence and make it easier to understand which data is already available and which information still needs to be collected.
For companies that have already launched traceability projects with Trusty, for example in connection with the European Union Deforestation Regulation (EUDR), the supply chain knowledge they have already built can provide a useful starting point. Existing mapping, geolocation data and documentation can be leveraged and complemented with the additional information needed to address the social dimension of risk, including information on suppliers, working conditions and due diligence activities.
The aim, therefore, is not to multiply compliance processes, but to build a more structured, continuous and verifiable approach to supply chain data management. This can reduce operational complexity and help companies reach 2027 with stronger knowledge of their supply chains and evidence that is easier to retrieve when needed.
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