In addition to the EU’s Corporate Supply Chain Due Diligence Directive (CSDDD) the European Union also adopted the EU Forced Labour Regulation (FLR). The FLR prohibits companies from selling products made with forced labour in EU markets. The law enters force on December 14, 2027, and in advance of that, the European Commission recently issued guidance clarifying the obligations for companies subject to the FLR. Linklaters discusses this guidance in a recent memo:
“As per the guidelines, the FLR imposes an obligation of result on economic operators; they must ensure that products made with forced labour do not enter, circulate within or leave the EU market, but how this is achieved is up to them…
Although the FLR does not impose specific due diligence requirements, due diligence is recognised as a useful tool to help companies comply with the FLR. The guidelines set out guidance on how due diligence can be applied in relation to forced labour, drawing heavily on the voluntary six-step OECD-based framework.”
This marks another forced labor ban as these laws become more popular globally. The US, Canada, and the UK are also taking measures to ban products produced with forced labor. Companies not currently engaged in supply chain tracing and due diligence should reconsider their position. As these laws expand, they are likely to become more prescriptive and may impose serious compliance obligations.
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