Update on the EU Forced Labour Regulation: What the European Commission’s New Guidelines Mean for Companies

On June 26, 2026, the European Commission published its long-awaited guidelines on the application of the EU Forced Labour Regulation (EU) 2024/3015. The EU Forced Labour Regulation prohibits the placing on the market, making available, and exporting of products made with forced labour. Unlike the German Supply Chain Due Diligence Act (LkSG) or the European Corporate Sustainability Due Diligence Directive (CSDDD), the EU Forced Labour Regulation applies to all companies that place, make available, or export products on or from the EU market, regardless of industry sector, company size, or registered office, and generally covers all types of products. The EU Forced Labour Regulation also applies regardless of whether the forced labour occurs within a company’s own operations or within its supply chain.

In the event of non-compliance with the EU Forced Labour Regulation, the competent authority may order a prohibition on placing, making available, or exporting the relevant products. It may also order affected products to be withdrawn or removed from the market.

The new guidelines are intended to support companies in practical implementation and, for the first time, provide concrete guidance on the measures that will be expected in practice. Although the guidelines are not legally binding, they are likely to significantly shape the future enforcement and supervisory practice of the competent authorities. Companies should therefore begin addressing the new guidance now, even though the EU Forced Labour Regulation will not apply until December 14, 2027.

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