EU Forced Labour Products Ban (Regulation (EU) 2024/3015)
All products may be removed from the EU market if linked to forced labour. This page summarizes the rule, enforcement flow, evidence expectations, and how suppliers and brands can prepare. Source materials are used only for internal synthesis—no downloads are provided.
What is new
- Applies to any product at EU borders and within the market; removal/disposal orders possible.
- Evidence-driven investigations; importers/suppliers need verifiable traceability and worker-level proof.
- Interplays with CSDDD/CSRD, Battery Regulation, CBAM, national supply chain laws.
Scope & triggers
- Forced-labour indicators anywhere in the chain, including deep tiers.
- High-risk flags: opaque origin, labour transfer schemes, XPCC/Xinjiang linkages, conflict/high-risk regions.
- Investigations can originate from NGO/media findings, customs intelligence, or partner-state inputs.
Evidence & Minimum Verifiable Dataset (MVD)
- Traceability: supplier tree to Tier 3–4, batch/lot and COO evidence.
- Workforce proof: contracts, payroll, hours, grievance logs, worker voice records.
- Site evidence: photos, audits with worker interviews; FPIC/community records where relevant.
- Data room: map evidence to regulatory triggers; maintain a rapid-response pack for customs queries.
Procedures for firms
- Pre-emptive HRDD: identify high-risk inputs; require MVD from suppliers.
- When notified: assemble evidence pack, engage buyers, prepare for removal/appeal pathways.
- Remediation: correct labour findings, document actions, update buyers/regulators.
Comparisons (EU Ban vs UFLPA vs CSDDD)
- EU Ban: product removal; broad scope; evidence-heavy; applies at border and in-market.
- UFLPA: rebuttable presumption on Xinjiang/XPCC; CBP detention process; strong evidence burden.
- CSDDD/CSRD: due-diligence/reporting duties; less product-specific but drives upstream HRDD and disclosure.
Use cases
- Chinese outbound suppliers: prepare MVD-ready traceability, worker/payroll/grievance proofs, and buyer-facing evidence packs.
- Brands/buyers: pair supplier data with independent verification where risk is high; align with EU and UFLPA expectations.
Need support? We offer readiness reviews, evidence pack design (MVD), and workshops for suppliers/brands facing EU and UFLPA enforcement. Contact: hello@esghub.hk.