On Dec. 12, 2024, the European Union’s Forced Labor Regulation (FLR) was published, prohibiting the placement, sale, and export of products made with forced labor on the EU market. This is the definitive and legally binding version of the FLR.
The prohibition on products made with forced labor, as set out in the FLR, and the resulting obligations and associated checks and enforcement, will take effect on Dec. 14, 2027. Nevertheless, some provisions requiring EU member states and the European Commission to prepare the framework for the application and enforcement of the FLR are already in effect (for example, in relation to the designation of competent authorities or the creation of forced labor databases). Companies operating in the EU would be well advised to begin surveying potential risks in their supply chains and establishing their own internal compliance programs.
Once the FLR fully takes effect, it will prohibit economic operators (meaning any natural or legal person, or association thereof) from placing or making available products made using forced labor on the EU market (including distance sales). It will also prohibit them from exporting such products from the EU.
The FLR’s definition of forced labor is that used in the Forced Labor Convention of the International Labor Organization (ILO). The ILO defines forced labor as “all work or service which is exacted from any person under the menace of any penalty and for which the said person...
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