COMPLIANCE DEEP DIVE
The EU Forced Labour Regulation: What Fashion Brands Must Prepare by 14 December 2027
From 14 December 2027, Regulation (EU) 2024/3015 prohibits economic operators from placing or making available on the EU market, or exporting, products made with forced labour, in whole or in part, at any stage of the supply chain. It applies to all products and to companies of every size. Enforcement runs through investigations: authorities first ask the companies concerned, unless that would jeopardise the outcome of the assessment, what they have done about forced labour risks, and a confirmed violation leads to a ban, the withdrawal of the products and their disposal.
This guide covers what the ban says, the dates, how an investigation runs and what evidence authorities may ask for, based on the regulation and on the Commission's Guidelines published in the Official Journal on 3 September 2026. It also covers where the Digital Product Passport fits: the regulation does not require one, but it names the passport's unique identifier as one way to identify a product.
14 Dec 2027
The date from which the prohibition applies (Article 39). The regulation entered into force on 13 December 2024; the Commission's Guidelines were published in the Official Journal on 3 September 2026.
30 working days
The time an economic operator has to answer the lead authority's request for information in the preliminary phase of an investigation (Article 17(2)).
No size threshold
The prohibition applies to every economic operator; the Commission states that it applies to companies of all sizes. SMEs get support measures and contact points (Article 10).
1. What the ban says
Article 3 is a single sentence: economic operators "shall not place or make available on the Union market products that are made with forced labour, nor shall they export such products". The definitions give it its reach. A "product made with forced labour" is one for which forced labour has been used "in whole or in part at any stage of its extraction, harvest, production or manufacture", including in the working or processing related to the product at any stage of its supply chain (Article 2, point 7). Forced labour takes its meaning from Article 2 of ILO Convention No 29, including forced child labour (point 1), and the regulation also addresses forced labour imposed by state authorities within the meaning of ILO Convention No 105 (point 2).
On the wording of Article 2, point 7, a garment can fall under the ban because of forced labour in the production of its raw materials or in any processing step, not only at the final manufacturing stage. Online sales are covered: a product offered for sale online or through other distance sales is deemed to be made available on the market if the offer is targeted at end users in the EU (Article 4).
Article 1 sets two limits. The regulation does not cover the withdrawal of products that have already reached end users in the EU (paragraph 2), and it "does not create additional due diligence obligations" for economic operators beyond those already provided for in Union or national law (paragraph 3).
2. Who it applies to, and the dates
The prohibition addresses economic operators. An "economic operator" is any natural or legal person or association of persons placing or making available products on the Union market or exporting products (Article 2, point 9). The Commission's page explaining how the regulation works lists manufacturers, importers, distributors, retailers and online sellers among the companies covered, and its implementation page states that the requirement applies to companies of all sizes, with dedicated support for SMEs.
| Date | What happens | Source |
|---|---|---|
| 13 December 2024 | The regulation enters into force. A small set of provisions, including those on the database, the guidelines and the notification of penalty rules, applies from this date. | Article 39 |
| 30 June 2026 | The Commission launches the Forced Labour Single Portal and a preparedness package. | Commission implementation page |
| 3 September 2026 | The Commission's Guidelines on the application of the regulation are published in the Official Journal (C/2026/4637). | Official Journal, C series |
| 14 December 2026 | Deadline for Member States to notify the Commission of their rules on penalties. | Article 37(3) |
| 14 December 2027 | The prohibition applies. The single information submission point for reporting suspected cases becomes available. | Article 39; Commission implementation page |
| 14 December 2029 | Deadline for the Commission's first evaluation of the enforcement and implementation of the regulation; further evaluations every five years thereafter. | Article 38(1) |
The database of forced labour risk areas or products was due by 14 June 2026 (Article 8(3)). On 3 October 2026, the Commission's page for the database described its purpose and content but marked it "Database in development". According to Article 8, the database is indicative and non-exhaustive, relies on independent and verifiable information from international organisations, in particular the ILO and the UN, or from institutional, research or academic organisations, and does not publicly disclose information that names economic operators directly.
3. How an investigation runs
Authorities follow a risk-based approach (Article 14). To prioritise, they use the following criteria as appropriate: the scale and severity of the suspected forced labour, including whether forced labour imposed by state authorities could be a concern, the quantity or volume of products placed or made available on the EU market, and the share of the suspect part in the final product. The Commission leads where the suspected forced labour takes place outside the EU; a competent authority of the Member State concerned leads where it takes place in that Member State (Article 15). When starting the preliminary phase, the lead authority focuses, to the extent possible, on the economic operators and, where relevant, product suppliers involved in the steps of the supply chain as close as possible to where the forced labour is likely occurring, and with the highest leverage to prevent, mitigate and bring it to an end (Article 14(4)).
| Stage | What happens | Time limits |
|---|---|---|
| Preliminary phase (Article 17) | Before opening an investigation, the lead authority asks the economic operators under assessment, and where relevant other product suppliers, what they have done to identify, prevent, mitigate, bring to an end or remediate forced labour risks in their operations and supply chains, unless that would jeopardise the outcome of the assessment. | Answer within 30 working days of receiving the request; the authority then concludes within 30 working days whether there is a substantiated concern. |
| Investigation (Articles 18 and 19) | Operators are told that an investigation has started, which products it covers and, unless this would jeopardise the outcome, why; they may submit documents and information. Field inspections are possible in exceptional situations; outside the EU, only with the consent of the operators concerned and subject to further conditions. | Operators are informed within 3 working days of the decision to open the investigation. For information the authority requests, it sets a deadline of at least 30 and at most 60 working days; operators may request an extension with a justification (Article 18(4)). |
| Decision (Articles 20 and 22) | If a violation is established: a prohibition on placing, making available and exporting the products; an order to withdraw them, including the removal of online listings; and an order to dispose of them or, where the parts found in violation are replaceable, of those parts. | The authority endeavours to adopt its decision or close the investigation within 9 months of opening it; deadlines for compliance are at least 30 working days (at least 10 for perishable goods, animals and plants). |
| Enforcement (Articles 23 to 30) | Competent authorities enforce the decision on the market; customs authorities rely on it to suspend and, where confirmed, refuse the release of matching products for free circulation or export. | Set by the decision and by the customs provisions. |
Two provisions carry particular weight. If an operator refuses to provide requested information or fails to provide it in time without valid justification, provides incomplete or incorrect information with the objective of blocking the investigation, provides misleading information, or otherwise impedes the investigation, the authority may establish a violation "on the basis of any other facts available" (Article 20(2)). And disposal follows the waste hierarchy: recycling or, where that is not possible, rendering the products inoperable (Article 25). For apparel, clothing accessories and footwear, the Commission's Guidelines (section 5.1.1.1) add that they can be destroyed in line with the ESPR derogations of Delegated Regulation (EU) 2026/296; see our destruction-ban guide.
Penalties are national and attach to non-compliance with a decision (Article 37). They must be effective, proportionate and dissuasive, and Member States must notify their rules to the Commission by 14 December 2026.
4. What evidence authorities may ask for
The regulation does not prescribe a due diligence system, but Article 17 asks what you have done. Section 4.7 of the Commission's Guidelines lists illustrative, non-exhaustive examples of the information that may be requested; the Guidelines themselves create no obligation for companies (section 6.1). For a fashion brand, the list works as a checklist:
| Category (Guidelines section) | Examples listed in the Guidelines (selection) |
|---|---|
| Your actions on forced labour risks (4.7.1) | Corporate policies and codes of conduct; procurement policies, supplier codes of conduct, contract clauses prohibiting forced labour, supplier onboarding and monitoring; sectoral risk assessments; a grievance mechanism; participation in multi-stakeholder or industry certification schemes; stakeholder engagement; due diligence reports; corrective action plans; third-party independent audit reports. |
| Working conditions at the site concerned (4.7.2) | Worker interviews and written testimonies; social audits; photos or videos of working conditions; worker lists, contracts, payrolls and financial records; survey results; evidence of remediation. |
| Identification of the product (4.7.3.1) | Traceability, trade, customs and shipping data; laboratory tests, including isotopic testing; description, name or brand, HS or CN codes, type, reference, model, batch or serial number, or the unique identifier of the digital product passport; chain-of-custody certificates and raw-material traceability data; documents linking the product to its raw-material source; bills of materials; certificates of origin; quantities and values; inventory and storage locations. |
| Supply chain structure and actors (4.7.3.2) | A description of the supply chain; a list of manufacturers, producers and suppliers for key production steps with name, trade name or registered trademark, contact details, national identification number and, where available, EORI number; supply chain maps covering tiers and sub-tiers, showing direct and indirect suppliers; ownership structures and relationships with suppliers and intermediaries. |
| Facilities, transactions and production (4.7.3.3 to 4.7.3.5) | Names, addresses and operating entities of facilities at key production stages, with geolocation data such as satellite imagery or GPS coordinates when available; purchase orders, invoices and receipts, packing lists, payment records, inventory records, shipping documents and import/export records; production orders, factory production-capacity reports and evidence that input and output volumes are consistent. |
The Guidelines add two qualifications. The list does not rank information in order of importance, and providing it "does not guarantee exculpation" (section 4.7). At the same time, the burden of proof lies with the authority: it must provide credible evidence that forced labour was used to make the products and that the operators under investigation made them available on the EU market or exported them (section 4.8.1.1).
5. Where the Digital Product Passport fits
The regulation does not require a Digital Product Passport. It mentions one in recital 56, which concerns the information customs authorities need to identify products covered by a ban decision: that information should include the product's identification under Union law, such as a type, reference, model, batch or serial number, "or the unique identifier of the digital product passport". The underlying power is Article 27: by delegated act, the Commission can identify products for which the person intending to place them under the customs procedures "release for free circulation" or "export" must provide or make available to customs information identifying the product, the manufacturer or producer and the product suppliers, unless customs legislation already requires it; implementing acts may specify the details of that information (Article 27(1) to (3)). On 3 October 2026, the Publications Office records showed no such delegated act. The Guidelines also list the passport's unique identifier among the data that identify a product in an investigation (section 4.7.3.1).
For textiles, the passport itself still awaits the ESPR delegated act that will set its content; see our DPP master timeline. The practical overlap is in the data. The supplier identities, supply chain maps, bills of materials and traceability evidence the Guidelines list are the same records a passport system draws on. On the wording of both texts, however, neither obligation replaces the other.
6. What to do now
Map the supply chain beyond tier 1. Among the information an authority may request, the Guidelines list supply chain maps covering tiers and sub-tiers and showing direct and indirect suppliers, and a list of the manufacturers, producers and suppliers for key production steps with their identification data (section 4.7.3.2).
Organise the evidence per product along the categories above, so that you can answer a request for information within 30 working days (Article 17(2)).
DPP AUDIT
An investigation can ask for product and supplier data.
Supplier lists, supply chain maps, bills of materials and traceability evidence are among the information an authority may request; having them retrievable per product makes an answer within 30 working days realistic. We help you structure that data once, for the Forced Labour Regulation and for your passport. Under NDA.
Start Your DPP AuditUse the Commission's tools. The Forced Labour Single Portal holds the Guidelines, the list of competent authorities and an SME preparedness checklist; competent authorities designate contact points for SMEs (Article 10). Check the risk database once it goes live.
Connect it with your other duties. The regulation adds no due diligence obligation of its own (Article 1(3)). The Guidelines point out that due diligence and reporting under other EU law, such as the Corporate Sustainability Due Diligence Directive (EU) 2024/1760 for large companies within its scope, can help show an operator's efforts during an investigation (section 6.2).
Frequently asked questions
Does the Forced Labour Regulation require a due diligence process?
Does it apply to small fashion brands?
What happens to clothing found to be made with forced labour?
Will customs stop shipments at the border?
Do we need a Digital Product Passport to comply?
Sources
- The regulationRegulation (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. Articles 1 to 4, 8, 10, 14, 15, 17 to 20, 22 to 30 and 37 to 39; recital 56. No corrigendum or amendment published to date. CELEX 32024R3015 ↗
- Commission GuidelinesCommission Notice – Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market (C/2026/4637, OJ C, 3.9.2026). Sections 4.7, 4.8.1.1, 5.1.1.1, 6.1 and 6.2. CELEX 52026XC04637 ↗
- ESPR derogations for apparel and footwearCommission Delegated Regulation (EU) 2026/296 of 9 February 2026 supplementing Regulation (EU) 2024/1781 of the European Parliament and of the Council by setting out derogations from the prohibition of destruction of unsold consumer products. CELEX 32026R0296 ↗
- Corporate sustainability due diligenceDirective (EU) 2024/1760 of the European Parliament and of the Council of 13 June 2024 on corporate sustainability due diligence and amending Directive (EU) 2019/1937 and Regulation (EU) 2023/2859, as amended by Directives (EU) 2025/794 and (EU) 2026/470. Referred to in section 6.2 of the Guidelines. CELEX 32024L1760 ↗
- Commission implementation pagesEuropean Commission, Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs: "Forced Labour Regulation" (implementation timeline, resources by role) single-market-economy.ec.europa.eu ↗, "What is the Forced Labour Regulation and how does it work?" (scope) single-market-economy.ec.europa.eu ↗ and the page on the database of forced labour risks single-market-economy.ec.europa.eu ↗.
Regulation (EU) 2024/3015, the Commission's Guidelines (C/2026/4637), Delegated Regulation (EU) 2026/296 and Directive (EU) 2024/1760 were read in the versions published by the EU Publications Office (EUR-Lex); the Publications Office records show no corrigendum, amendment or delegated act under Article 27 of Regulation (EU) 2024/3015 as of 03.10.2026. The Commission pages were accessed on 03.10.2026. This is general information, not legal, financial or investment advice.