EU Releases Forced Labour Regulation Guidelines

The European Commission has released its first set of guidelines for the EU Forced Labour Regulation, which takes effect December 14, 2027. The regulation introduces a sweeping ban on placing, selling, or exporting any products made with forced labour on or from the Union market. Its scope is exceptionally broad, applying to all companies of any size, sector, or location, and covers forced labour risks within a company’s own operations and throughout its entire supply chain. Penalties for non-compliance include orders to prohibit market access and withdraw or remove affected products. While the new guidelines are not legally binding, they provide the first practical details on expected due diligence measures and are expected to heavily influence the enforcement practices of member state authorities. Companies with any exposure to the EU market should begin reviewing the guidelines now to assess and adapt their supply chain compliance programs ahead of the 2027 deadline.