European UnionDelayed
Corporate Sustainability Due Diligence Directive
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
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A market prohibition on products made with forced labour at any stage of the supply chain, applying from 14 December 2027.
Commission adopted its implementation guidelines on 26 June 2026 and launched the Single Portal and risk database on 30 June.
In plain language
The EU FLR bans the sale of goods made with forced labour anywhere in the supply chain, applying to companies of all sizes with no exemption for smaller entities. Unlike the approach taken by the United States with the Uyghur Forced Labor Prevention Act (UFLPA), the EU FLR does not treat an entire region as presumptively guilty. Instead, EU authorities investigate specific cases, weighing the severity of the suspected harm, the volume of goods involved, and how significant forced labour is to the finished product.
In cases where goods are flagged for suspected forced labour, EU customs authorities can seize and order the destruction of the shipment. Companies under investigation are expected to produce evidence covering their full supply chain, which creates pressure to obtain that evidence from suppliers in advance. It is critical here to note that suppliers will not be able to rely solely on certifications and voluntary standards to prove their compliance to the regulation.
The EU FLR's ban on goods with forced labour in their supply chains applies from 14 December 2027. The European Commission adopted its implementation guidelines on 26 June 2026 and launched them on 30 June 2026, alongside the Forced Labour Single Portal and a forced labour risk database. The guidelines set out how authorities will select and prioritise cases, what evidence they will request, and what voluntary due diligence looks like in practice.
Obligations
Products made with forced labour at any tier cannot be sold in, or exported from, the EU market
Operators must respond to information requests and evidence demands from investigating authorities within set deadlines.
Where forced labour is established, products must be withdrawn, donated, recycled or destroyed at the operator cost.
Timeline
Regulation (EU) 2024/3015 adopted by the Council.
Commission preparing the risk database, guidelines and the Union Network Against Forced Labour Products.
Commission adopted its implementation guidelines, C(2026) 4386, on 26 June and launched them on 30 June with the Forced Labour Single Portal, the risk database and a provisional list of national competent authorities.
Prohibition and enforcement powers apply.
Changelog
Corrected the guidelines date: adopted on 26 June 2026 and launched with the Single Portal and risk database on 30 June; application date stated exactly.
Entry updated with progress on the Commission risk database and draft guidance.
Exposed export value at full application, across the ten tracked origins · Figures come from UN Comtrade. For each country we use what its buyer markets reported importing, rather than what the country itself reported exporting, because several tracked countries report to Comtrade late or not at all. Every share is measured against that country's exports to the nine regulated markets this index tracks, not against its total exports to the world, because no reliable world total exists for countries that under-report. European Union figures add up all twenty seven member states. The European product breakdown by chapter is estimated from the four largest importers, Germany, France, the Netherlands and Italy, and scaled up to the full twenty seven member total, so it captures which products dominate without understating any single one. · methodology
Same jurisdiction
Scope is now 5,000 employees and EUR 1.5 billion turnover, with fines capped at 3 percent; the guidelines consultation closed on 24 July 2026.
Read →Revised reporting standards published on 21 September 2026 and in force from 10 November, with the value chain cap now final.
Read →Leather left the scope on 18 September 2026, when Delegated Regulation (EU) 2026/2102 entered into force.
Read →