The EU Forced Labour Regulation: From Due Diligence to Product-Level Liability
For years, the standard of care in responsible sourcing has been defined by effort: documented processes, supplier assessments, demonstrated risk awareness. The EU Forced Labour Regulation (EU) 2024/3015, applying from 14 December 2027, shifts that logic entirely. The question is no longer whether a company followed the right procedures, but whether a specific product was made with forced labour at any stage of its value chain. As the Commission has put it, all EU companies – regardless of size – must ensure that products made with forced labour do not enter or leave the EU market, and: “How this is achieved is up to them.”
