WHAT IS THE AIM OF THE REGULATION?
Regulation (EU) 2024/3015 lays down rules prohibiting economic operators1 from placing and making available on the European Union (EU) market, or exporting from it, products made with forced labour2, to improve the functioning of the internal market and contribute to the fight against forced labour.
KEY POINTS
Prohibition of products made with forced labour
The prohibition applies to all products, regardless of their sector, type or origin (domestic or imported), including when only a part of the product was made with forced labour. It covers any use of forced labour at any stage of production, manufacture, harvest, extraction or processing. Products offered through distance sales, including online sales, are also subject to prohibition if the offer targets end users in the EU.
Implementation
The regulation will be implemented through decisions establishing that a specific product violates the prohibition of products made with forced labour. Such decisions will be adopted at the end of a two-step investigation process carried out by the European Commission for forced labour cases outside the territory of the EU and by EU Member States’ competent authorities for cases in their national territory. Member States must notify the Commission of their designated competent authorities by 14 December 2025.
Risk-based approach to investigations
The competent authorities and the Commission assess all available information using a risk-based approach to identify potential violations and prioritise investigations:
- authorities prioritise investigations taking into account the product volumes, the severity of suspected forced labour and the share of the part of the final product suspected to have been made with forced labour;
- authorities focus on economic operators based on their proximity to the risk source in the supply chain, their size and resources, their leverage to eliminate forced labour and the complexity of their supply chain.
Preliminary investigation phase
Before opening a formal investigation, authorities conduct a preliminary phase to assess the available information.
- Economic operators may be required to submit information on due diligence, mitigation, prevention and remediation efforts. The lead competent authority may choose not to request information if there is a risk that the outcome of the assessment might be jeopardised.
- Operators generally have 30 working days to respond.
- The preliminary assessment should conclude within 30 working days after receiving the information.
Investigation phase
Where a substantiated concern of forced labour is identified, the authorities will launch the investigation phase:
- the authorities can request additional information from the economic operators and, in exceptional situations, may carry out field inspections;
- operators will have between 30 and 60 working days to respond;
- the investigation should conclude within a reasonable period of time, to the extent possible not exceeding nine months.
Decisions and review
If the use of forced labour is confirmed, the lead competent authority adopts binding decisions prohibiting the placing or making available on the market and export of the affected products and ordering economic operators to withdraw and dispose of the products:
- decisions are published and contain the investigation’s findings, timelines for compliance and information to allow the identification of the banned products;
- economic operators may request a review by submitting new substantial information within 30 working days of notification;
- lead competent authorities may modify or withdraw decisions based on such new information.
Enforcement and penalties
The competent authorities of Member States enforce decisions and impose penalties on economic operators who fail to comply. The penalties must be effective, proportionate and dissuasive. Member States must establish their penalty systems by 14 December 2026. In determining penalties, authorities may take into account factors such as the gravity and duration of the violation and the degree of cooperation by the economic operator.
Role of customs authorities
Customs authorities contribute to enforcement by carrying out controls on products entering or leaving the EU market.
- customs authorities suspend the release for free circulation or export of prohibited products and inform the competent authorities;
- if the competent authorities confirm that the prohibition applies to the products in question, the customs authorities refuse the release and seize the products for disposal.
Union Network Against Forced Labour Products
A Union Network Against Forced Labour Products is established to coordinate action across the EU:
- the network includes representatives of Member States, the Commission and, where appropriate, customs authorities.
- the Commission coordinates its operation and organises regular meetings.
Information and communication systems
The regulation establishes a digital infrastructure to support enforcement and information exchange:
- a new module under the existing information and communications system for market surveillance (ICSMS) is used to manage investigation data and decisions;
- automated data transfer between the ICSMS and customs systems is established in three phases:
- decision-sharing for customs risk management (within two years of the adoption of the implementing act setting the respective functionalities),
- case management via the EU single window environment for customs3 (within four years of the adoption of the implementing act setting the ICSMS functionalities),
- extraction of customs data related to the implementation of the regulation.
Database of forced labour risks
The Commission establishes a publicly available, indicative and non-exhaustive database of forced labour risks:
- this database identifies risks linked to specific products, product groups or geographic areas, with a focus on widespread and severe risks;
- it uses verifiable information from sources such as the International Labour Organization (ILO), the United Nations and research institutions;
- the database provides authorities and economic operators with information to help identify and assess forced labour risks.
Guidelines
The Commission makes available implementation guidelines to support competent authorities and economic operators:
- the guidelines for competent authorities include information to facilitate the implementation of the regulation, including benchmarks for risk-based assessments in investigations, applicable standards of evidence and risk indicators of forced labour;
- the guidelines for economic operators focus on due diligence in relation to forced labour (including in relation to state-imposed forced labour, best practices to eliminate and remediate forced labour and possible guidance for specific sectors and types of suppliers) and on engagement with competent authorities;
- guidelines also cover other issues such as customs aspects, submission of information by stakeholders and penalties for non-compliance imposed by Member States.
Single information submission point
A central platform will allow any natural or legal person or association to submit information on suspected forced labour violations. Submissions will be made via the forced labour single portal, which will be available in all official EU languages. They must follow templates and include factual and verifiable evidence. Submissions that are incomplete, unfounded or made in bad faith will be discarded. Submitters will be informed of the outcome of their submission’s assessment.
Support measures for small and medium-sized enterprises (SMEs)
The Commission develops specific support tools to help small and medium-sized enterprises comply with the regulation:
- measures include guidance, training and online resources on due diligence and forced labour indicators;
- Member States designate contact points for small and medium-sized enterprises, which may include existing help desks.
International cooperation
The regulation builds on international standards prohibiting the use of forced labour and promotes international cooperation to enhance enforcement and share information on forced labour risks:
- cooperation includes structured dialogues with non-EU countries and international organisations;
- the exchange of information may include risk data but excludes information on ongoing investigations;
- EU delegations contribute to raising awareness and facilitating information sharing.
Amendments to existing legislation
The regulation amends Directive (EU) 2019/1937 on the protection of persons who report breaches of EU law (see summary).
FROM WHEN DOES THE REGULATION APPLY?
The regulation applies from 14 December 2027. However, certain provisions apply earlier, including the designation of competent authorities, the publication of the implementation guidelines and the risk database, and the setting of national penalty systems.
BACKGROUND
For further information, see:
KEY TERMS
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Economic operators. Individuals or companies placing or making available products on the EU market or exporting products from the EU.
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Forced labour. Work or service demanded from a person under the threat of a penalty and for which the person has not offered themselves voluntarily.
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EU single window environment for customs. An EU-wide electronic system that facilitates the exchange of information between customs and other competent authorities, enabling the sharing and reuse of data submitted by economic operators to streamline border controls and ensure coordinated enforcement of EU rules.
MAIN DOCUMENT
Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labour on the Union market and amending Directive (EU) 2019/1937 (OJ L, 2024/3015, 12.12.2024).
RELATED DOCUMENTS
Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law (OJ L 305, 26.11.2019, pp. 17–56).
Successive amendments to Directive (EU) 2019/1937 have been incorporated into the original text. This consolidated version is of documentary value only.
Directive 2011/36/EU of the European Parliament and of the Council of 5 April 2011 on preventing and combating trafficking in human beings and protecting its victims, and replacing Council Framework Decision 2002/629/JHA (OJ L 101, 15.4.2011, pp. 1–11).
See consolidated version.
Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 765/2008 and (EU) No 305/2011 (OJ L 169, 25.6.2019, pp. 1–44).
See consolidated version.