The EU Forced Labour Regulation: What UK businesses need to know
8 April
While much of the business world’s attention has been fixed on the push and pull of the CSDDD negotiations, a rather significant piece of legislation slipped without fanfare onto the statute books at the end of 2024.
Article by Louise Herring, Director, Inherently Human
The EU Forced Labour Regulation – published in the Official Journal on 12 December 2024 and formally entering into force the following day – represents something brand new in the regulatory landscape. And unlike the CSDDD, which has spent the past year being whittled down, this one is moving in one direction only.
What is the EUFLR and why does it matter?
The EU Forced Labour Regulation is, at its core, a product ban. From 14 December 2027, any product made in whole or in part using forced labour – at any stage of its production, from raw material extraction through to final manufacture – will be prohibited from being placed on, or exported from, the EU market. That includes products sold online. It covers all sectors, and critically, it applies to all companies, regardless of size where they are incorporated.
This is different from the CSDDD, which focused on larger companies and created due diligence obligations. The FLR creates a market access consequence. If your product is found to have forced labour in its supply chain, it can be seized at the border, withdrawn from shelves, or both. There is no minimum turnover threshold. A UK SME exporting to Europe is in scope; as is a multinational.
The regulation uses the ILO definition of forced labour – all work or service exacted from any person under the threat of a penalty and for which the person has not offered themselves voluntarily – and explicitly includes forced child labour within this definition.
How will it be enforced?
The enforcement model is twofold. Where forced labour occurs within the EU, national competent authorities in the relevant member state will investigate. For forced labour occurring outside the EU – which is, realistically, where most of the risk lies for companies with global supply chains – the European Commission leads the investigation. Member states were required to confirm their designated competent authorities by December 2025. A Forced Labour Single Portal is being built. A database of high-risk products and geographic areas is due to be published by June 2026, alongside detailed compliance guidelines.
Investigations will be risk-based, prioritising cases where the severity and scale of harm is greatest. The regulation pays particular attention to state-imposed forced labour – situations where governments coerce citizens into work – flagging documented examples in regions including Xinjiang, North Korea, and Turkmenistan.
Importantly, a company under investigation can demonstrate good faith by providing evidence of its due diligence efforts. This means that businesses that have genuinely worked to understand their supply chains (and can evidence this) are in a very different position to those that have not.
What does this mean for UK businesses specifically?
For UK businesses that trade into EU markets, this is direct and consequential. If you manufacture, import or sell goods into the EU, and forced labour can be demonstrated anywhere in your supply chain, you face having those goods blocked or withdrawn. There is no carve-out for smaller companies. There is no ‘we didn’t know’ defence if the evidence suggests you should have.
For UK businesses that don’t sell directly into the EU, the picture is more indirect but no less real. If you supply into the supply chains of companies that do sell into the EU, you will face increasing pressure to demonstrate your own practices. The regulation’s downstream effects are already being felt – procurement teams in larger companies are beginning to ask harder questions of their suppliers.
Then there’s the question of what the UK does next. The Modern Slavery Act 2015 remains the primary tool for UK supply chain transparency, and for all its significance as a landmark piece of legislation, a House of Lords committee concluded in October 2024 that the UK’s response to modern slavery ‘has not kept up with the advances of other nations.’ The government published updated guidance under the Act in March 2025 – the first significant refresh in nearly a decade and extremely thorough in its additions – but the underlying legal requirements remain largely unchanged. Mandatory due diligence, a forced labour import ban: all recommended, none yet legislated.
What we are seeing is political momentum building. The Joint Committee on Human Rights opened a new inquiry into forced labour in global supply chains in January 2025. The Business & Trade Committee warned this spring that the UK risks becoming a ‘dumping ground’ for goods linked to exploitation if it doesn’t act. The Independent Anti-Slavery Commissioner has been clear that mandatory due diligence needs to happen. The direction of travel is towards closer alignment with the EU model. How quickly government moves is, as ever, the open question.
The practical reality
It’s three years before the FLR becomes enforceable – and that might feel like plenty of time. But for businesses with complex, multi-tier supply chains in high-risk sectors – garments, electronics, agriculture, construction materials – where the thread from finished product back to raw materials can run through dozens of countries and hundreds of suppliers – time is of the essence.
Meaningful supply chain due diligence takes years to build. It requires transparency of supply chains, building supplier relationships, ongoing monitoring, evidence of actions, building trust, and time. It requires internal alignment between procurement, compliance, and leadership. And it requires businesses to see their supply chains for what they really are: a network of human relationships, each carrying risk and responsibility.
The businesses best placed to demonstrate compliance in 2027 are the ones doing the work now. That means supply chain mapping – really understanding what you buy, who makes it, and where. It means risk assessment, prioritised by geography, sector, and the vulnerability of the workers involved. It means building supplier engagement that goes beyond a questionnaire to something more like a conversation. And it means keeping records as evidence that you have really looked, and acted on what you found.
What we’re hearing from clients
What strikes me working with businesses across the human rights and ethical trade space is that the regulatory uncertainty – the lack of clear guidance, the to and fro of the CSDDD negotiations, the Omnibus revisions, the slow pace of UK reform – hasn’t stopped the best of them from pressing on.
The companies we find most inspiring aren’t waiting for the regulations to arrive before they start taking action.
They understand that the workers in their supply chains don’t become more or less at risk based on what Brussels or Westminster decides to legislate. The harm is real, now.
Those businesses will be far better positioned when December 2027 arrives – because they’ll be drawing on years of genuine engagement with their supply chains. And in a world where investors, customers, and employees are paying ever closer attention to how companies source and operate, that readiness will increasingly matter long before any enforcement body comes knocking.
The EU Forced Labour Regulation is a significant step. Its enforcement will determine how much it ultimately delivers for the people it exists to protect. But for UK businesses weighing up how to respond, the answer is straightforward: get started.
