Forced Labor Risk

Eliminate the risk of forced labor in your supply chain – in line with EU requirements

Forced labor in global supply chains is not only a serious violation of human rights but also poses real legal, reputational, and financial risks for businesses. Since December 2027, the EU has been fully enforcing the Forced Labor Regulation , banning the marketing of products made with forced labor at every stage of production and distribution.

What is forced labor?

On 19 November 2024, the EU adopted a Regulation of the European Parliament and of the Council on the prohibition of products manufactured using forced labour on the Union market and amending Directive (EU) 2019/1937.

The regulation is based on the definition contained in Convention No. 29 of the International Labor Organization (ILO) , which defines forced labor as any form of work or service exacted from a person under the threat of punishment, performed without their free will. In practice, it may include, among others:

Physical or mental coercion – forcing someone to work through threats, intimidation or the use of force.
Work as part of so-called "debt relief" – forced through financial manipulation or unfair contracts.
Retention of identity documents to restrict the freedom of movement of employees.
Excessive working hours in degrading or unsafe conditions , in violation of fundamental workers' rights.

Entrepreneur's obligations under FLR Compliance

concern the implementation of appropriate procedures

at individual stages of supply chains.
Pursuant to the Regulation, entrepreneurs must:

Monitor your supply chains

- to identify the risk of forced labour at any stage of the chain.

Prevent and eliminate violations

– by taking corrective and preventive actions.

Implement due diligence procedures

– in line with regulatory guidelines and best market practices.

Report actions taken

– in particular large enterprises subject to the reporting obligation under the CSRD Directive.

What will be the consequences of failing to comply with the new rules?

If the competent authority finds that products have been placed on the market, made available on the market or exported in violation of the prohibition, it shall immediately issue a decision , which may include:

Prohibition on placing on the market or making available on the EU market and prohibition on exporting them outside the EU.
An order to withdraw from the market products already introduced or made available in the EU, or to remove content or offers relating to these products from online platforms.
An order to remove products or their parts from circulation if they violate the regulations – in the case of spare parts, it will be necessary to eliminate only the elements covered by the ban.

The Regulation does not impose an obligation to withdraw products that have already reached end users within the EU.

The main assumptions of the regulation:

Prohibition of placing on the market and making available

It is prohibited to place or make available on the EU market products manufactured under forced labour conditions.

Ban on exporting goods from the EU

The ban also applies to the export of products from the territory of the Union that were produced using forced labour.

The new regulations cover all products

Both domestic and imported – regardless of the sector, region of origin or stage of production.

Information system

The regulation provides for the introduction of an information system to support the implementation of the ban and facilitate controls by customs authorities.

Planned aid for SMEs

The EC plans to develop detailed guidelines tailored to the needs of SMEs to facilitate their implementation.

Processing of personal data

If it is necessary to process personal data in order to enforce the prohibition, this will be in accordance with personal data protection regulations.

Check out the 'FLR & Evidence Hub' module in Reporting Assistant

Green Reporting provides an advanced SaaS tool – Forced Labor Risk & Evidence Hub , which allows you to:

Identify high-risk suppliers and transactions using customs data, industry intelligence and satellite analytics.
Assess the level of risk for individual products, countries of origin and stages of the supply chain.
Collect and manage evidence of the absence of forced labor – in one secure repository.
Generate evidence reports ready for submission to EU customs authorities in the event of an inspection or blocking of goods.

At Green Reporting, we help companies go through this process consciously and without unnecessary downtime. We offer:

Your company's readiness audit in terms of Forced Labor Regulation.
Workshops for purchasing, compliance and logistics teams – identification of risk areas.
Configure the 'Forced Labor Risk & Evidence Hub' module in Reporting Assistant.
Creation of a due diligence procedure regarding and managing the process of a transparent and ethical supply chain for your organization.
Continuous support and updates to the risk database along with monthly reports.

It is not just advisory support. It is a real partnership in building an advantage in the new, sustainable economy.

EU FLR implementation schedule

The new EUFLR regulation aims to eliminate forced labour from global supply chains by introducing uniform requirements across the European Union.

Below are key dates that will help your organization prepare for full compliance.

💡 Why is it worth acting now?

The process of preparing an organization for EUFLR requirements takes time—from mapping the supply chain, through implementing due diligence procedures, to creating an evidence repository. Our Forced Labor Risk & Evidence Hub module in Reporting Assistant allows you to automate and document each step in line with European Commission expectations.