{"id":11532,"date":"2026-09-03T20:44:18","date_gmt":"2026-09-03T18:44:18","guid":{"rendered":"https:\/\/empact.nu\/forced-labour-regulation-who-made-your-product\/"},"modified":"2026-09-03T21:16:13","modified_gmt":"2026-09-03T19:16:13","slug":"forced-labour-regulation-who-made-your-product","status":"publish","type":"post","link":"https:\/\/empact.nu\/en\/insights\/forced-labour-regulation-who-made-your-product\/","title":{"rendered":"Do you know who made your product? The Forced Labour Regulation is coming"},"content":{"rendered":"\n<p class=\"wp-block-paragraph\">On 26 June 2026, the European Commission published its guidelines on the Forced Labour Regulation (FLR), together with the Forced Labour Single Portal and a risk database. That makes clear how the ban on products made with forced labor will work in practice from 14 December 2027. Do you know under what conditions your products were made, all the way back to the raw material? Who in your organization can answer that question? And how long would it take?<\/p>\n\n\n\n<figure class=\"wp-block-image size-large\"><img fetchpriority=\"high\" decoding=\"async\" width=\"1024\" height=\"572\" src=\"https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier-1024x572.webp\" alt=\"Hands of a garment worker guide dark blue fabric under the needle of an industrial sewing machine\" class=\"wp-image-11546\" srcset=\"https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier-1024x572.webp 1024w, https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier-300x168.webp 300w, https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier-768x429.webp 768w, https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier-1536x858.webp 1536w, https:\/\/empact.nu\/wp-content\/uploads\/2026\/09\/forced-labour-regulation-naaiatelier.webp 1920w\" sizes=\"(max-width: 1024px) 100vw, 1024px\" \/><\/figure>\n\n\n\n<p class=\"wp-block-paragraph\">In this article we make that concrete:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li>we explain what exactly the regulation prohibits;<\/li>\n\n\n\n<li>we show the role due diligence plays once an investigation starts;<\/li>\n\n\n\n<li>we describe where forced labor sits in a supply chain and how to recognize it;<\/li>\n\n\n\n<li>we name who takes this on within the organization, and where to start.<\/li>\n<\/ul>\n\n\n\n<h2 class=\"wp-block-heading\">Forced Labour Regulation: a ban without a threshold<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Regulation (EU) 2024\/3015 prohibits placing products made with forced labor on the European market, making them available and exporting them from the EU. No turnover threshold, no headcount threshold. It therefore affects every sector and everyone in the chain: the manufacturer, the importer and just as much the web shop that only resells. Products made within the EU are covered too, as is the stock already sitting in your warehouse on 14 December 2027. Services, by the way, fall outside the scope.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The law does not prescribe how you keep forced labor out of your chain, only that the product must not have been made with it. That makes the FLR an obligation of result. No duty of care, no reporting obligation, no mandatory supply chain investigation. It is about the product itself.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">In an investigation, what you know about your chain counts<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">How does such an investigation work? The competent authority first requests information and assesses within 30 working days whether there is a substantiated concern. If a formal investigation follows, you usually get 30 to 60 working days to demonstrate that the product was not made with forced labor, and a decision normally follows within nine months. The guidelines state that documented due diligence can be important evidence in such an investigation. If you do not know where your raw materials come from, that weakens your position. And the extent to which you cooperate is taken into account in the sanction.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">As a guide, the Commission points to the six steps of <a href=\"https:\/\/empact.nu\/en\/insights\/due-diligence-in-european-sustainability-legislation-a-brief-introduction\/\">due diligence from the OECD guidelines<\/a>: embed, identify, prevent, monitor, communicate and remediate. The same framework underlies <a href=\"https:\/\/empact.nu\/en\/csddd-advice\/\">the CSDDD<\/a>. With the Omnibus directive of February 2026, the CSDDD was narrowed to companies with more than 5,000 employees and more than 1.5 billion euros in turnover, applying from July 2029. The FLR has no such threshold and takes effect well over a year and a half earlier. So whether you fall under the CSDDD does not matter for the FLR. What matters is how well you know your own chain.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">What we see in practice: that is also the right order. You map your value chain because you want to know how your product is made and because you want to be able to intervene when something goes wrong there. That this also gets you through an investigation is the consequence, not the goal. And that consequence is not small: products are withdrawn from the market and destroyed, and the decision is published on the portal. It applies to everyone who sells that same product, so also to your customers. The Netherlands has not yet designated a competent authority, but that changes nothing about the date on which the ban takes effect.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">How do you recognize forced labor in your chain?<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">Forced labor is rarely recognizable from a single signal. The ILO describes a series of indicators that together form a picture:<\/p>\n\n\n\n<ul class=\"wp-block-list\">\n<li><strong>Wages:<\/strong> wages are withheld or paid only after a long time.<\/li>\n\n\n\n<li><strong>Identity documents:<\/strong> the employer keeps passports or identity papers.<\/li>\n\n\n\n<li><strong>Debt:<\/strong> someone is tied to their employer through recruitment fees or advances.<\/li>\n\n\n\n<li><strong>Freedom of movement:<\/strong> it is restricted, at work or in the housing.<\/li>\n\n\n\n<li><strong>Vulnerability and intimidation:<\/strong> a dependent position is abused and threats are made.<\/li>\n<\/ul>\n\n\n\n<p class=\"wp-block-paragraph\">The Commission&#8217;s risk database, live since 26 June 2026, identifies products and regions with a high risk. Forced labor imposed by a state gets the highest priority in the guidelines, because it is structural and affects large groups of people. Remediation through your supplier is usually not possible there.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The subject also plays out closer to home. In 2026, the Netherlands Labour Authority is focusing its criminal investigations on labor exploitation, legally something different from forced labor, although the signals overlap. What the dependence on migrant workers means for Dutch supply chains, we described earlier in <a href=\"https:\/\/empact.nu\/en\/insights\/without-migrant-workers-no-production-but-at-what-cost\/\">without migrant workers no production<\/a> and in <a href=\"https:\/\/empact.nu\/en\/insights\/from-low-skilled-labor-to-skilled-workers-labor-migration-requires-a-different-conversation\/\">from low-skilled labor to skilled workers<\/a>. In early 2025, the Dutch Ministry of Foreign Affairs had the forced labor risks in Dutch imports mapped (Assessing Forced Labour Risks in Dutch Imports), a useful starting point to hold your own purchasing against.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">In the conversation with a supplier, it helps to keep asking. Who paid the recruitment fees? Is the housing tied to the contract? When are wages paid, and who keeps the identity documents? A certificate obviously says something, but it does not replace such a conversation, because that is where you hear what happens on the work floor.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Governance: this is a question for the board<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">The guidelines do not prescribe a governance structure, but in practice this subject lands on the board&#8217;s table. After all, it touches purchasing decisions, supplier choices and contracts, and in a sanction it matters whether there was intent or negligence. Who is responsible for what belongs to <a href=\"https:\/\/empact.nu\/en\/governance\/\">governance<\/a>, which is why we recommend placing that responsibility at board level. In the execution, purchasing, legal, sustainability and compliance are obviously at the table.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">The hardest trade-off arises the moment something is actually found. The guidelines expect you to focus first on remediation when a risk is identified, meaning you resolve it together with your supplier. Responsible disengagement is the last step, although in the case of state-imposed forced labor it is often the only one left. That trade-off also affects the people at the other end of the chain. Leaving a supplier does not, after all, solve their situation.<\/p>\n\n\n\n<h2 class=\"wp-block-heading\">Where do you start? Five steps<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">How you <a href=\"https:\/\/empact.nu\/en\/insights\/a-more-sustainable-value-chain-5-steps-to-really-make-an-impact\/\">map your value chain<\/a>, we described earlier in five steps. For forced labor risks, we keep to this order:<\/p>\n\n\n\n<ol class=\"wp-block-list\">\n<li><strong>Responsibility:<\/strong> appoint someone who is responsible for forced labor risks and lay down in policy what you expect from suppliers.<\/li>\n\n\n\n<li><strong>Risk products:<\/strong> start with the product groups and countries of origin from the Foreign Affairs report and the risk database, and trace them back to raw material level.<\/li>\n\n\n\n<li><strong>The supplier conversation:<\/strong> assess suppliers on the ILO indicators and not only on certificates.<\/li>\n\n\n\n<li><strong>Documentation:<\/strong> keep origin information, audits, contracts and the follow-up of signals together in such a way that you can deliver them within 30 working days.<\/li>\n\n\n\n<li><strong>Remediation:<\/strong> agree in advance what happens when a signal comes in, when you remediate and when you disengage.<\/li>\n<\/ol>\n\n\n\n<h2 class=\"wp-block-heading\">One process for FLR, CSDDD and EUDR<\/h2>\n\n\n\n<p class=\"wp-block-paragraph\">You do not need to set up a separate process for this. The FLR and the CSDDD refer to the same OECD framework, the EUDR asks for the same supply chain knowledge, and you need that knowledge for your scope 3 emissions and your CSRD reporting as well. Whoever sets this up thoroughly once is prepared for several laws and, above all, sees where in the chain real impact can be made. Not an additional legal exercise, but a practical way forward for your entire chain.<\/p>\n\n\n\n<p class=\"wp-block-paragraph\">At Empact, we help organizations <a href=\"https:\/\/empact.nu\/en\/esg-due-diligence-risk-management\/\">implement due diligence in a practical way<\/a>: starting small with one important risk, and linking the process to CSRD reporting and the broader ESG goals.<\/p>\n\n","protected":false},"excerpt":{"rendered":"<p>From 14 December 2027, products made with forced labor may not enter the EU. What does the Forced Labour Regulation ask of your chain, and where do you start?<\/p>\n","protected":false},"author":14,"featured_media":11546,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[257,1],"tags":[],"class_list":["post-11532","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-insights","category-inzichten"],"_links":{"self":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11532","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/users\/14"}],"replies":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/comments?post=11532"}],"version-history":[{"count":3,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11532\/revisions"}],"predecessor-version":[{"id":11549,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/posts\/11532\/revisions\/11549"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/media\/11546"}],"wp:attachment":[{"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/media?parent=11532"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/categories?post=11532"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/empact.nu\/en\/wp-json\/wp\/v2\/tags?post=11532"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}