EU Council adopts ban on products made with forced labour

On 19 November 2024, the EU Commission adopted regulations prohibiting products in the EU market that are made using forced labour (the Regulation).

The main purpose of the Regulation is to prohibit products made using forced labour from being sold in, or exported from, the EU market – it will apply to any product where forced or child labour is used, whether in whole or in part, at any stage of the product's supply chain. Whilst the Regulation does not expressly impose additional due diligence obligations on businesses, to ensure compliance, businesses will need to have in place clear policies and processes to identify, monitor and (where necessary) address any instances of forced or child labour in their operations and supply chains. This includes assessing suppliers, maintaining transparent records, and responding to investigations by EU authorities.

Adoption by the EU Council is a significant step in the Regulations' legislative journey, and cements the EU in its journey to become a global ethical regulator. After being signed by the President of the European Parliament and the President of the Council, the Regulation will be published in the Official Journal of the European Union and will enter into force on the day following its publication. It will apply three years after the date of entry into force and, as such, will impact goods sold into or from the EU from the end of 2027.

The Regulation is intended to operate alongside other EU sustainability regulations (such as the Corporate Sustainability Due Diligence Directive), and it is expected to have noticeable impacts on businesses that sell their products into or from the EU.

For more detail on the reach of the Regulation, or to find out how it might impact your business, please visit our previous post here or get in touch with one of our experts.