Pushing back against global forced labour with the EU’s new forced labour regulation
Samira Rafaela
May 20, 2025
#EU / Western Europe
#Corporate responsibility and lead firms
The European Union is taking decisive steps to address forced labour on a global scale. As of December 2024, the EU Forced Labour Regulation (EU FLR) has officially entered into force. It marks a significant opportunity for the EU to reaffirm its role as a promoter of human rights –– rewriting the rules of the game. The European Commission and Member States are now preparing for full implementation by December 2027. For companies, this signals a major shift: their products may soon face heightened scrutiny and a ban.
According to the International Labour Organization (ILO), forced labour generates an estimated USD 236 billion annually across various industries. Think about the agriculture and fishing industry, the textile industry and domestic work. Concrete examples are the Uyghur’s human rights violations in China, cotton workers in Turkmenistan and child labor in the Congo. These figures highlight the urgent need for systemic reform. Under the EU FLR, companies will be required to ensure that their global supply chains are free from forced labour. If not, their products may be flagged in a public database and barred from reaching consumers within the EU—resulting in reputational damage and significant financial losses. This mechanism is intended to disrupt economic incentives for unethical practices and create a fairer playing field, especially for businesses committed to ethical sourcing who are often undercut by competitors relying on exploitative practices. The EU FLR has the potential to address child labour as well. The ILO estimates that 11.8 million women and girls and 3.3 million children are currently a victim of forced labour around the world.
Under Article 13, the EU FLR encourages cooperation with non-EU countries to address forced labour risks. The regulation encourages international exchange of information and best practices, acknowledging that the fight against forced labour requires a uniform global approach. In this context, collaboration with countries such as the United States will be critical. The U.S. Department of Labor maintains a database of goods produced with forced labour and enforces the Uyghur Forced Labor Prevention Act (UFLPA), which similarly identifies regions at risk—particularly those involving state-imposed labour such as Xinjiang, China. Coordinated bans from both the EU and U.S. could put strong pressure on companies to reform their supply chains and disengage from high-risk areas. This collective action may generate long-term improvements by incentivizing companies to eliminate forced labour throughout the supply chain.
The EU FLR also places emphasis on products likely linked to state-imposed forced labour. These high-risk products will become part of a special list in the EU FLR database. They may receive priority for investigations and could be banned from entering the EU market. In principle, all goods found to be produced using forced labour—regardless of origin—can be subject to bans.
The regulation outlines a two-stage investigation process. If a product is filed for investigation, companies have 30 days during a preliminary review to provide evidence about their supply chain, including due diligence, risk mitigation, and remediation practices. Based on this response, regulators will decide whether to proceed to a full investigation. If the presence of forced labour is confirmed, the product will be publicly listed in an EU database and banned across all 27 Member States. This includes both import and export.
The EU FLR complements broader EU efforts to hold companies accountable, particularly through the proposed Corporate Sustainability Due Diligence Directive (CSDDD). However, this directive is currently facing political challenges in Brussels. Proposed revisions could weaken its scope, such as limiting corporate responsibility to only first-tier suppliers and removing civil liability for human rights violations. This could affect the effectiveness of the EU FLR, which also relies on strong due diligence standards to detect and prevent forced labour. Most instances of forced labour occur deeper in supply chains—at tiers 3 and 4—not per se in direct supplier relationships. If companies are not obligated to look beyond their immediate business partners, identifying and addressing forced labour will become more challenging.
Remediation obligations under both the CSDDD and EU FLR are still relatively weak. The current version of the EU FLR does not impose a legal duty to remediate. However, the European Commission plans to issue guidance encouraging companies to implement meaningful remediation processes. It will also gather information on whether remediation occurred in identified cases. Additionally, it will gather gender- and age-disaggregated data to better understand who is affected. In future evaluations of the regulation, the Commission will review the topic of remediation to consider a remedy mechanism as part of the EU FLR.
Despite growing attention to the issue and in particular the EU FLR –– many companies remain underprepared to prevent forced labour in their supply chains. The key lies in gaining a comprehensive understanding of supply chains, identifying actors and risks, and implementing effective monitoring systems. The EU FLR will motivate companies to take these steps. While the regulation is product based, the reputational risks associated with repeated product bans will encourage broader policy changes within firms.
Understanding the definition of forced labour—and how to detect it—is essential. As the ILO notes, forced labour is “hard to count, hard to see.” Data remains limited, and many companies are reluctant to disclose information related to these risks. Greater transparency will be necessary to effectively target root causes and build long-term solutions.
To assist companies with due diligence, the Cornell Global Labor Institute has developed 25 Labor Outcomes Metrics. These tools are aligned with the CSDDD and provide a practical approach for identifying and mitigating labour exploitation. Metrics focused on workforce conditions—such as working hours, freedom of movement, freedom of association, and fair compensation—can serve as early indicators of forced labour in the supply chain.
Ultimately, education and capacity building will be key. Companies must train staff, especially those involved in procurement and compliance, to recognize signs of exploitation. Equally important is the development of local partnerships and proactive engagement with affected communities and local and national governments. Rather than waiting for enforcement of the EU FLR –– companies should take initiative now to align with these new standards and protect their supply chain operations—and workers—from the harms of forced labour.
According to the International Labour Organization (ILO), forced labour generates an estimated USD 236 billion annually across various industries. Think about the agriculture and fishing industry, the textile industry and domestic work. Concrete examples are the Uyghur’s human rights violations in China, cotton workers in Turkmenistan and child labor in the Congo. These figures highlight the urgent need for systemic reform. Under the EU FLR, companies will be required to ensure that their global supply chains are free from forced labour. If not, their products may be flagged in a public database and barred from reaching consumers within the EU—resulting in reputational damage and significant financial losses. This mechanism is intended to disrupt economic incentives for unethical practices and create a fairer playing field, especially for businesses committed to ethical sourcing who are often undercut by competitors relying on exploitative practices. The EU FLR has the potential to address child labour as well. The ILO estimates that 11.8 million women and girls and 3.3 million children are currently a victim of forced labour around the world.
Under Article 13, the EU FLR encourages cooperation with non-EU countries to address forced labour risks. The regulation encourages international exchange of information and best practices, acknowledging that the fight against forced labour requires a uniform global approach. In this context, collaboration with countries such as the United States will be critical. The U.S. Department of Labor maintains a database of goods produced with forced labour and enforces the Uyghur Forced Labor Prevention Act (UFLPA), which similarly identifies regions at risk—particularly those involving state-imposed labour such as Xinjiang, China. Coordinated bans from both the EU and U.S. could put strong pressure on companies to reform their supply chains and disengage from high-risk areas. This collective action may generate long-term improvements by incentivizing companies to eliminate forced labour throughout the supply chain.
The EU FLR also places emphasis on products likely linked to state-imposed forced labour. These high-risk products will become part of a special list in the EU FLR database. They may receive priority for investigations and could be banned from entering the EU market. In principle, all goods found to be produced using forced labour—regardless of origin—can be subject to bans.
The regulation outlines a two-stage investigation process. If a product is filed for investigation, companies have 30 days during a preliminary review to provide evidence about their supply chain, including due diligence, risk mitigation, and remediation practices. Based on this response, regulators will decide whether to proceed to a full investigation. If the presence of forced labour is confirmed, the product will be publicly listed in an EU database and banned across all 27 Member States. This includes both import and export.
The EU FLR complements broader EU efforts to hold companies accountable, particularly through the proposed Corporate Sustainability Due Diligence Directive (CSDDD). However, this directive is currently facing political challenges in Brussels. Proposed revisions could weaken its scope, such as limiting corporate responsibility to only first-tier suppliers and removing civil liability for human rights violations. This could affect the effectiveness of the EU FLR, which also relies on strong due diligence standards to detect and prevent forced labour. Most instances of forced labour occur deeper in supply chains—at tiers 3 and 4—not per se in direct supplier relationships. If companies are not obligated to look beyond their immediate business partners, identifying and addressing forced labour will become more challenging.
Remediation obligations under both the CSDDD and EU FLR are still relatively weak. The current version of the EU FLR does not impose a legal duty to remediate. However, the European Commission plans to issue guidance encouraging companies to implement meaningful remediation processes. It will also gather information on whether remediation occurred in identified cases. Additionally, it will gather gender- and age-disaggregated data to better understand who is affected. In future evaluations of the regulation, the Commission will review the topic of remediation to consider a remedy mechanism as part of the EU FLR.
Despite growing attention to the issue and in particular the EU FLR –– many companies remain underprepared to prevent forced labour in their supply chains. The key lies in gaining a comprehensive understanding of supply chains, identifying actors and risks, and implementing effective monitoring systems. The EU FLR will motivate companies to take these steps. While the regulation is product based, the reputational risks associated with repeated product bans will encourage broader policy changes within firms.
Understanding the definition of forced labour—and how to detect it—is essential. As the ILO notes, forced labour is “hard to count, hard to see.” Data remains limited, and many companies are reluctant to disclose information related to these risks. Greater transparency will be necessary to effectively target root causes and build long-term solutions.
To assist companies with due diligence, the Cornell Global Labor Institute has developed 25 Labor Outcomes Metrics. These tools are aligned with the CSDDD and provide a practical approach for identifying and mitigating labour exploitation. Metrics focused on workforce conditions—such as working hours, freedom of movement, freedom of association, and fair compensation—can serve as early indicators of forced labour in the supply chain.
Ultimately, education and capacity building will be key. Companies must train staff, especially those involved in procurement and compliance, to recognize signs of exploitation. Equally important is the development of local partnerships and proactive engagement with affected communities and local and national governments. Rather than waiting for enforcement of the EU FLR –– companies should take initiative now to align with these new standards and protect their supply chain operations—and workers—from the harms of forced labour.
