EU Forced Labour Regulation Guidelines: What Brands Must Know

Forced labour has become one of the defining fault lines in global trade policy. What was once treated largely as a matter of voluntary corporate ethics is increasingly being written into hard law, with governments reaching for enforcement tools that carry real commercial consequences. The direction of travel is unmistakable: in June 2026, the US government opened Section 301 investigations into forced labour concerns across 60 countries, a clear signal of how far up the legislative agenda the issue has climbed worldwide.

The European Union moved earlier than most. In November 2024, it adopted the Forced Labour Regulation (FLR), which bans the sale or export of any product made with forced labour from the EU market. At the time, the regulation attracted little attention, as the Omnibus package and its focus on the Corporate Sustainability Due Diligence Directive (CSDDD) dominated the conversation. That has now changed. The European Commission has published its Guidelines on the FLR, offering the clearest picture yet of how the regime will operate and what it will require of companies.

For apparel and footwear brands, the detail is where the challenge lies. Below, our Supply Chain Policy Expert Annica Edl unpacks what the FLR is and sets out the key takeaways from the new guidelines.

What is the Forced Labour Regulation?

The FLR was adopted on 19th November 2024, banning the sale or export of all products made with forced labour from the EU market. This legislation applies to all products, regardless of company size or sector, and will take effect on 14th December 2027. The FLR differs from other EU laws tackling supply chain traceability, such as the EU Deforestation Regulation or the CSDDD: rather than adding more requirements for companies, its provisions are dedicated to establishing an enforcement framework among national authorities and the EU Commission, and outlining their investigation process. This is why the guidelines are such an important piece to the FLR puzzle. 

What are the FLR Guidelines?

These guidelines, alongside the Forced Labour Single Portal, are intended to help companies and governmental authorities prepare adequately for the EU Forced Labour ban. The Forced Labour Single Portal will be the portal where all decisions are published, information submissions can be made, and authority contacts can be found. One and a half years ahead of the application deadline, the guidelines provide granular insights for how the EU Forced Labour ban will impact apparel and footwear brands, detailing how enforcement authorities will use a risk-based approach to select cases, what type of information will be requested from brands, and what actions are required once a violation of the forced labour ban has been found. Below, we have captured key takeaways from the guidelines.

Key insights from the FLR Guidelines

Short timelines to provide granular due diligence documentation (and more)

If an investigation is started, the affected company will have to provide specifically requested information and documents in a very short time window. In preliminary investigations, authorities will request to see a brand’s forced labour due diligence - not just a human rights policy, but documentation of a complete compliance system within the organisation - within 30 working days. On top of that, if a full investigation is launched, authorities could request more information on the products under investigation, ranging from bills of materials, information on inventory and storage locations and raw material traceability data to supply chain mapping and supplier lists, again within a short timeframe. 

FLR Decisions apply beyond the company they name:

This is perhaps the most interesting takeaway from the guidelines. Once it is determined that a company’s product was made with forced labour, the company is ordered to withdraw & dispose of the non-compliant products and to remediate the forced labour in the affected stage of the supply chain. However, the guidelines say that such a decision “applies not only to the economic operators named in that decision, but also to any other economic operator that places or makes available such products on the EU market or exports them.” This means that even if only company A is named in the decision, companies B and C, which source from the same facilities where forced labour was found, are also expected to.

What does this mean for the apparel industry?

On paper, the FLR does not impose due diligence requirements, and this is made very clear in both legal text and the guidelines. Thus, brands could continue business as usual and would not be non-compliant with FLR. However, if an investigation is started, the FLR procedural steps are very specific, and timelines are tight. To comply, every brand selling into the EU or exporting products from the EU will need to: 

• appoint a department internally which takes the lead on FLR requests and can liaise with up to 28 different authorities (27 Member States and the EU); 

• establish a forced labour due diligence system that can capture up to tier 4 level granularity;

• keep records of this system and its ongoing improvement; and 

• continuously monitor FLR decisions published on the Forced Labour Single Portal for potential impact.

In short, the FLR will require companies to have robust due diligence systems specific to forced labour in place by December 2027. 

How 2BPolicy supports brands & retailers

EU and global ESG legislation is complex, and the challenge for many businesses is now shifting from understanding what is coming to determining how to comply and implement requirements effectively.

Combining deep legislative expertise with practical industry experience, 2B Policy helps organisations cut through the noise, identify what applies to their business, prioritise where to focus, and translate regulatory requirements into clear, practical action. Whether you need support interpreting legislation, upskilling internal teams, establishing the right governance structures, developing an implementation roadmap, or embedding ongoing compliance expertise within your organisation, we tailor our support to your needs.

2B Policy acts as your trusted source of truth on ESG regulation, helping you move from policy to implementation with clarity and confidence. We would welcome the opportunity to discuss how we can support your organisation

— AnnicaEdl (Sustainability Policy Manager)