The EU Forced Labour Regulation (EUFLR) will significantly change how companies manage forced labor risks in their supply chains. As an official partner to the European Commission in the design and development of the EUFLR database, the CORE team brings first-hand insights into emerging requirements and practical implications.
the core team is your euflr implementation partner.
On this page, we provide a complete overview of the EUFLR and offer practical guidance to businesses preparing for its implementation. Scroll down to find everything you need to know about the EUFLR and what it means for your business.
WHAT DO YOU NEED TO KNOW ABOUT
THE EU FORCED LABOUR REGULATION?
What does the EUFLR do?
What does the EUFLR do?
The EUFLR prohibits placing or making available products made with forced labor on the EU market, as well as exporting such products from the EU.
Who does the EUFLR apply to?
Who does the EUFLR apply to?
It applies to:
- All companies and individuals (economic operators),
- All products, regardless of origin, and
- All stages of production, including extraction, harvesting, manufacturing and processing.
This means that forced labor risks at any point in the supply chain can place a product in scope of the EUFLR.
When does the EUFLR apply?
When does the EUFLR apply?
The EUFLR was published on 12 December 2024 and entered into force the following day on 13 December 2024.
However, the EUFLR will apply starting from 14 December 2027.
What counts as forced labor?
What counts as forced labor?
The EUFLR uses the ILO’s definition: any work or service exacted from a person under the threat of a penalty, and for which the person has not offered themselves voluntarily.
It explicitly includes forced child labor and forced labor imposed by state authorities.
Does the EUFLR require due diligence?
Does the EUFLR require due diligence?
The EUFLR does not create additional due diligence obligations for companies beyond those already established in existing EU or national corporate sustainability laws, such as the Corporate Sustainability Due Diligence Directive (CSDDD) and the German Supply Chain Act (LkSG).
In practice, companies already conducting human rights due diligence in line with the UN Guiding Principles, OECD Guidance, or existing due diligence laws are already addressing forced labor risks. However, the EUFLR introduces a new level of scrutiny and will require companies to go further in terms of depth, evidence and responsiveness.
How will the EUFLR be enforced?
How will the EUFLR be enforced?
The EUFLR introduces a risk-based approach to assess likelihood of violations.
Authorities will prioritize products based on:
- The scale and severity of suspected forced labor
- The quantity or volume of products on the EU market
- The share of the part potentially linked to forced labor in the final product
Authorities must rely on “all relevant, factual and verifiable information”, including the EU’s forced labor database, risk indicators, stakeholder input and submissions through the Commission’s information portal.
Authorities will also consider companies’ leverage to address forced labor, proximity to the risk, size and resources and the complexity of the supply chain.
How will authorities investigate?
Does the EUFLR require due diligence?
Preliminary phase:
Before launching a formal investigation, authorities will first ask companies to demonstrate the due diligence measures they have already taken.
This includes how you:
- Identify and assess forced labor risks
- Prevent and mitigate those risks
- End or remediate impacts where they occur
Companies will have 30 days to respond.
This means due diligence must already be in place before any request is received. Companies aligned with international standards (UNGPs, OECD Guidelines) or existing due diligence laws will be better prepared to respond effectively.
Investigation phase:
Authorities then have an additional 30 days to determine whether there is a substantiated concern that justifies a formal investigation.
If an investigation is opened, companies will be notified by the supervisory authority and asked to provide detailed information on the product and its components as well as its manufacturer, producer and supplier. Investigations may also involve field inspections.
What happens if a violation is confirmed?
What happens if a violation is confirmed?
If a violation of the EUFLR is confirmed, the supervisory authority will, within nine months, adopt a decision that may include:
- A prohibition on placing or making the product(s) available on the EU market and exporting them
- An order to withdraw the product(s) from the EU market or remove relevant online content
- An order to dispose of the product(s)
Where only parts of a product are affected, replaceable components must be removed and substituted. However, if the product is of strategic or critical importance, the competent authority may allow it to be temporarily withheld from the market while the forced labor issue is addressed, instead of requiring disposal.
Companies may request a review of the decision at any time by providing evidence of compliance with the prohibition, demonstrating that forced labor has been eliminated in relation to the product.
If the decision is upheld and the company fails to comply, penalties will be imposed. These must be “effective, proportionate and dissuasive” and will take into account factors such as the seriousness and duration of non-compliance, the company’s track record, its level of cooperation with authorities and any other mitigating or aggravating circumstances.
What should companies expect before 2027?
What should companies expect before 2027?
By June 14, 2026, the European Commission is mandated to publish a forced labor database that provides indicative information on forced labor risks in specific geographic areas or products. The CORE team was selected to contribute to the development of this EUFLR database.
In addition, the Commission will also develop implementation guidelines for economic operators, competent authorities and stakeholders to better understand and comply with the regulation.
the core team is your euflr implementation partner.
We meet you where you are.
Our services support you at every stage of your EUFLR preparation: from building internal capacity and understanding where forced labor risks sit in your supply chain to developing a concrete plan to address them.
Selected CORE projects:
– Developing the EUFLR database to be published by the European Commission (in cooperation with Ecorys and Human Rights at Work)
– Commissioned by the Dutch Ministry of Foreign Affairs to develop a framework for prioritizing Dutch imports linked to forced labor risks (together with our partner Human Rights at Work)
– Advising multiple EU and US-based corporations on assessing and mitigating the forced labor risks in their value chains
THIS IS HOW WE WILL SUPPORT YOU
EUFLR ReADINESS training
WHAT:
You receive a tailored, interactive training session for those corporate functions leading or supporting EUFLR implementation. This training builds the knowledge and practical skills you need to recognize forced labor risks, respond to regulatory triggers, and navigate EUFLR requirements with confidence.
HOW:
We design each session around your company’s context, your sector, your supply chain, your existing practices. The training builds your team’s understanding of the EUFLR’s requirements and provisions and can include elements such as live simulations of investigation scenarios and structured debriefs to capture lessons learned and surface gaps.
forced labor risk assessment
WHAT:
You receive a prioritized list of products and commodities exposed to forced labor risks, aligned with the EUFLR’s three-factor risk-based approach and ready to integrate into your existing human rights risk assessment frameworks and due diligence.
HOW:
Our approach adapts to your starting point.
If you are starting from scratch, we identify risks from the ground up by mapping your imported and exported products, highlighting those with high inherent risk, and prioritizing them using the EUFLR’s three-factor approach, including scale and severity, market volume, and share in the final product, together with the 11 ILO forced labor indicators. We also assess countries of origin and associated risk levels.
If you already have a human rights risk assessment in place, we refine and strengthen it to align with EUFLR requirements. This includes applying the Regulation’s three-factor approach and the 11 ILO indicators, adding a targeted layer of analysis that integrates with your existing processes rather than duplicating them.
euflr roadmap
WHAT:
You receive a tailored action plan and implementation roadmap with clear timelines for effectively addressing forced labor risks in your value chain.
HOW:
We review and assess specific measures to address your forced labor risks and develop a prioritized set of recommended actions to help close gaps and track the effectiveness of your risk management processes. It is developed collaboratively to ensure organizational alignment and ownership as a basis for successful implementation.
Need a commodity-specific assessment?
We offer deep-dive assessments that examine specific supply chains and sourcing regions, including the root causes of forced labor risks within them. The result is a granular understanding of where risks concentrate and why, laying the foundation for developing effective mitigation measures.
We build on this assessment by providing you with recommended measures to mitigate the risks connected to the specific commodity.
Not sure where to start?
Reach out.
We’ll build the right path forward.
Cecilia Barral Diego
cecilia@peopleatcore.com
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