EU Forced Labour Regulation 2025: The Import Ban and What Exporters Must Prove

How the EU Forced Labour Regulation Works#

The EU Forced Labour Regulation creates a prohibition on placing or making available on the EU market, or exporting from the EU, products made with forced labour. It covers all products — goods of any kind, from any country, including EU-made goods. The regulation does not create a positive list of banned countries or companies; instead, it establishes an investigative and decision-making process. Competent authorities in member states, and the European Commission for cases with wider EU significance, can open investigations on the basis of substantiated concern that forced labour has been used. Investigations can be initiated by authorities on their own initiative or on the basis of submissions from third parties.

Investigative Authority and the Burden of Proof#

The regulation distinguishes between two investigation phases. The preliminary phase involves gathering information to determine whether there is substantiated concern. If concern is established, a formal investigation is opened. During the formal investigation, economic operators (manufacturers, importers, or distributors) must provide information about their supply chains. Critically, in areas identified by the Commission as involving state-imposed forced labour — meaning government programmes compelling citizens to work — the burden of proof is reversed. Operators must demonstrate that forced labour was not used, rather than authorities proving that it was. This distinction matters enormously for products from regions such as Xinjiang, where the Commission has signalled concern about state-imposed labour programmes. AskBiz tracks the developing list of high-scrutiny regions and product categories.

Highest-Risk Sectors and Products#

The European Commission has published guidance identifying sectors and geographies of highest concern. These include cotton and textiles (particularly from Xinjiang), polysilicon for solar panels, tomato products, fish products from certain regions, and electronics assembly. Beyond geography, certain labour-intensive processing stages are flagged as higher risk regardless of country: garment stitching, electronics assembly, raw material extraction and processing. For UK exporters to the EU, the risk is not just about UK operations — it extends to every tier of your supply chain. A UK manufacturer using components sourced from a high-risk region in their EU-bound product is within scope. The regulation explicitly covers goods that are only partly made with forced labour.

What UK Exporters to the EU Must Demonstrate#

There is no official certification scheme under the regulation, but economic operators need to be able to demonstrate due diligence — specifically that they have identified forced labour risks in their supply chains and taken steps to address them. Practical steps include supply chain mapping to identify who supplies your suppliers, risk assessments for each tier, supplier questionnaires and audits for higher-risk supply relationships, and grievance mechanisms. Third-party audit standards such as Sedex SMETA, BSCI, and SA8000 are not automatically sufficient, but they contribute to a demonstrable due diligence record. Operators in lower-risk supply chains with transparent provenance will face fewer difficulties. The regulation aligns broadly with the UN Guiding Principles on Business and Human Rights.

Penalties and Remedies#

Where a decision finds that products were made with forced labour, the remedies are significant: products can be withheld from EU market entry, seized at the border, or withdrawn from the market if already placed. Operators must donate, recycle, or destroy the goods — they cannot simply re-export them. Member states set their own penalties for non-compliance with decisions, and the regulation requires these to be effective, proportionate, and dissuasive. The regulation becomes fully applicable in December 2027, but the Commission is already building the implementing framework. Businesses exporting to the EU should treat this as a 2025-2027 preparation window, not a distant deadline.

• The EU Forced Labour Regulation (Regulation (EU) 2024/3015) entered into force in December 2024, with the prohibition applying from December 2027.
• Any product made wholly or partly with forced labour — including state-imposed forced labour — can be banned from sale on the EU market, seized at the border, or ordered to be withdrawn.
• UK exporters to the EU must be able to demonstrate their supply chains are clean.