• On 5 March 2024, the European Union reached political agreement on new legislation that will ban products and their component parts made with forced labour from being placed on the EU market, further supplied within the EU or exported from the EU.
  • Suspected uses of forced labour will be investigated – with noncompliant products subject to import and export bans and mandatory market withdrawal, including from online marketplaces – and the authorities will be able to require mandatory recycling, donation or disposal of products.
  • A new ‘Forced Labour Single Portal’ with guidelines for companies and enforcement authorities will allow for the centralisation of enforcement efforts.
  • Greater supply chain visibility will help mitigate businesses’ risks of costly noncompliance – including product seizures, customs detentions, fines, litigation and brand impact.

The EU’s ban on products made with forced labour regulation (FLR) will apply to products which in whole or in part benefited from forced labour. Supplementing the existing EU rules combatting human trafficking, the FLR now will be subject to formal approval and is likely to apply across all EU member states from mid-2027. The full text of the provisional agreement has not been published and is expected to become publicly available in the next few weeks. In the meantime, based on what we know at this stage, our alert here contains some highlights of the agreement.

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