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The EU Forced Labour Regulation: Why 2027 Matters

The EU passed a law in 2024 that almost nobody in the SME world has felt yet. It has no reporting duty for small companies. No questionnaire season. No annual filing. And yet it might be the single most expensive EU regulation for any business that sells physical products into the bloc.

Regulation (EU) 2024/3015 bans products made with forced labour from the EU market. It starts applying on 14 December 2027. Here's why a business of any size should treat that date as a deadline, not a footnote.

What the regulation does

The core is brutally simple: no product made with forced labour anywhere in its supply chain may be placed on the EU market, made available on it, or exported from it. It applies to all products, from all countries, at any step of the chain — extraction, harvesting, manufacturing, processing. There is no size threshold, no industry exemption, and no grandfathering. A nine-person importer of woven baskets is in scope exactly like a multinational garment group.

Enforcement works differently from most EU rules you've met. Companies have no reporting obligation. Instead, the European Commission and member state authorities investigate — risk-based, using a database of forced labour risk areas, a single portal for substantiated concerns, and cooperation with customs. Anyone can submit a concern. When an investigation concludes a product involves forced labour, the authorities can order its withdrawal, recall, and disposal — at the company's expense — and customs can stop the goods at the border. The ban's teeth are in the product, not in a fine schedule.

How this differs from CSDDD

People confuse the two, understandably. The Corporate Sustainability Due Diligence Directive (CSDDD) imposes due diligence obligations on large companies and, through them, on their suppliers — we covered it here. The Forced Labour Regulation is a different animal: a product ban enforced against whoever placed the product on the market, big or small. CSDDD makes big companies run processes; this regulation makes everyone's products liable.

It also sits alongside the US UFLPA, the UK and Australian modern slavery acts, Canada's Bill S-211 and the German LkSG — a patchwork of regimes that all pull on the same thread: prove where your goods come from. We covered the US side in the UFLPA guide.

What a small business should do before 2027

You can't investigate your whole chain, and the regulation doesn't expect a small firm to. What it expects is that you know your chain and can show your work. Concretely:

  1. Map your tiers. Who makes your product? Who supplies their key inputs? You don't need every farm in every country — you need the named, real facilities and where they are.
  2. Keep purchase records. Invoices, delivery documents, supplier contracts, dates and volumes. The trail itself is the defence.
  3. Ask the four questions. We published the questions to ask suppliers that cover forced labour risk: recruitment fees, worker passports, subcontracted production, and living conditions. Ask them, record the answers.
  4. Watch the risk areas. When the Commission publishes forced labour risk areas for specific products and regions, treat them as a procurement red flag, not a footnote.
  5. Document decisions. "We stopped using that subcontractor in 2026 because of X" is exactly the kind of evidence an investigator looks for.

The businesses that will lose products at the border in 2028 are the ones with no records at all. Absence of evidence is not evidence of absence — it's a reason to investigate further.

One dossier per product, kept alive

The practical shape of this is a product dossier: supply chain map, supplier declarations, purchase records, and the answers to those four questions, per SKU or product family. It needs to be updatable — suppliers change, risk areas change — and retrievable in a hurry, because customs and authorities don't work on your calendar.

A structured, dated, verifiable page per product, published so your EU importer and the authorities can see the chain of evidence, is the difference between a tense week and a destroyed quarter. Add your suppliers to the same system and the change that matters — a facility, a material, a subcontractor — arrives as a notification on your side instead of a surprise at the border. That's exactly the workflow Sustalium builds for — supplier-linked due diligence evidence at €10 per document, one live URL per product.

December 2027 sounds far away. It's three procurement cycles. The companies that start mapping now will be selling through the deadline; the ones that start in 2027 will be explaining gaps. Choose your group.

How Sustalium Helps with Forced Labour Due Diligence

  • One dossier per product — supply chain map, supplier declarations and purchase records on a live, dated page.
  • Supplier-linked notifications — a facility, material or subcontractor change on your supplier's side arrives as a notification on yours.
  • Evidence ready for anyone — your EU importer and the authorities can see the chain of evidence without chasing you.

Start the Dossier Before 2027 Starts the Clock

Build the evidence chain now, keep it linked to your suppliers, and have it verifiable before December 2027. Start with a free demo: no card needed, publish the verifiable version when you are ready.

Start Your Due Diligence Dossier →

Frequently Asked Questions

Is there a size exemption?

No. The regulation applies to all products and all operators, with no revenue or employee threshold. A nine-person importer is in scope like a multinational.

Do I have to file anything?

There is no reporting duty for companies. The obligation is that your products must not involve forced labour — and you must be able to show your chain and your checks.

How will enforcement find products?

Through a risk-based database, a single portal for substantiated concerns, and customs cooperation. Anyone can submit a concern, and authorities investigate.

Last updated: September 23, 2026

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