Regulation (EU) 2024/3015 · application from December 2027
Not a fine. A market ban – and the goods stop moving.
The Forced Labour Regulation does not primarily punish. It removes the product from the market. If you cannot evidence origin within the authority’s deadline, you lose the shipment.
The regulation prohibits placing on the EU market, making available or exporting products made wholly or partly with forced labour. Authorities may investigate, recall goods, withdraw them and order disposal. Unlike reporting duties, the goods themselves are at stake.
Investigations follow a risk-based approach drawing on databases, submissions and publicly available information. What decides the outcome for a company is the ability to evidence at short notice where a product and its inputs were made – and what was already done to check that chain.
Who is affected
- Every economic operator making products available in the EU or exporting them – regardless of size or sector.
- Swiss and Liechtenstein exporters, as soon as their goods reach the EU market.
- Companies with inputs from regions flagged in relevant reporting.
- Trading tiers without production of their own, who must still answer for origin.
What counts
- Traceability
- Being able to name the production sites of the main inputs for each product.
- Risk-based approach
- Knowing which regions, commodity groups and processing stages carry elevated risk, and checking them specifically.
- Readiness
- Holding documents so they can be produced within short official deadlines.
- Contractual basis
- Information and audit rights towards suppliers that reach their suppliers too.
- Responsiveness
- Prepared alternative sources for goods from risk regions.
How SCRM covers it
A chain, not a contact list
Supplier, upstream supplier and production site linked – the precondition for any answer.
Risk regions flagged
Country and commodity profiles surface exposed chains before anyone asks.
Assessment history
What was checked and when is the difference between diligence and assertion.
Alternative sources on file
A documented alternative for critical suppliers instead of an idea.
Frequently asked
Is there an exemption for small companies?
The prohibition applies regardless of size. Enforcement is meant to take size and resources into account, but the ban itself has no threshold.
Is a supplier declaration enough?
Hardly on its own. It is one element alongside origin data, risk assessment and, where risk is elevated, checks of your own.
When should we be ready?
Before application, not after. Collecting data across several tiers takes months; the authority’s deadline in a suspected case is days.
As of July 2026. Not legal advice.