On 12 December 2024, the European Union (“EU”) published Regulation 2024/3015 (“Regulation”) in the EU Official Journal, which prohibits the sale of products made with forced labour in the EU market. Certain provisions of the Regulation have already entered into force, and the Regulation will be fully applicable starting from 14 December 2027. The Regulation introduces significant legal provisions to prevent products made with forced labour from entering the EU market and ensures that such products are excluded from any stage of the supply chain.

Scope

The Regulation strictly prohibits the sale, distribution, and export of products made with forced labour in the EU market. This prohibition applies to all products and their components, regardless of geographic origin, including both EU-produced and imported goods.

However, products that have already reached end users within the EU market are excluded from the scope of this Regulation. Furthermore, the Regulation does not introduce additional due diligence obligations beyond those already established under EU or national laws.

Key Provisions

The concept of “forced labour” in the Regulation is defined in accordance with the International Labour Organization’s Convention No. 29. It includes any work or service performed under coercion or the threat of penalty, against a person’s free will. Child labour, when involving coercion or threats, is also considered a form of forced labour.

The term “supply chain,” as defined in the Regulation, encompasses all activities involved in the extraction, processing, production, and distribution of a product. Consequently, products that contain components produced through forced labour at any stage of the supply chain fall under the scope of this prohibition. For instance, if a single component of a product is made with forced labour, the entire product is deemed non-compliant. Additionally, products sold via online platforms or through distance sales methods are also subject to this Regulation.

Implementation

Competent authorities responsible for enforcing the Regulation will be designated by each Member State. These authorities will monitor prohibited products, identify violations, and implement necessary sanctions. To ensure their transparency, impartiality, and effectiveness, Member States must guarantee that the competent authorities have sufficient funding and expertise. Furthermore, competent authorities are expected to collaborate with other relevant national bodies and their counterparts across the EU.

The European Commission will provide guidelines to facilitate the implementation of the Regulation. Additionally, an EU-wide “Union Network Against Forced Labour Products” will be established, comprising representatives from Member States and the European Commission. This network, which may involve customs authorities as necessary, will oversee the implementation of the Regulation and coordinate efforts among Member States.