The EU forced labour ban applies in 14 months. The guidance is out; the risk database is not.

The EU Forced Labour Regulation has been law since December 2024. It applies from 14 December 2027. From that date, products made wholly or partly with forced labour may not be placed on the EU market, made available on it, or exported from it.

It covers every business, of any size, and any product, including raw materials and agricultural goods. Online offers aimed at EU customers count as making a product available.

What has happened in 2026

• The guidelines are published. The Commission adopted them in late June 2026, about two weeks after the legal deadline. They run to more than 70 pages, were published in the Official Journal on 3 September, and are not binding. They explain the definition of forced labour, how authorities will prioritise cases, and what due diligence they expect to see, built on OECD guidance.
• The risk database is not. The Regulation required a database of forced-labour risk areas and products by June 2026. At the time of writing, 9 October, it has still not been published.
• No delay has been proposed. We have found no Commission proposal to postpone or amend the Regulation.

How enforcement will work

National authorities investigate risks inside their own country. The Commission leads where the suspected forced labour is outside the EU. Both use a risk-based approach that weighs the scale and severity of the abuse, the volume of products and the complexity of the supply chain.

If an investigation finds forced labour, the decision bans the product from the EU market and from export, and orders products already on the market to be withdrawn and disposed of. Customs authorities can hold goods at the border. Penalties are set by each member state.

Has a customer asked where your inputs come from? The checklist at the end of this note sets out the 12 things an authority or customer will ask. Get the checklist →

Why UK suppliers should act now

The ban follows the product, not the seller. A UK manufacturer selling into the EU, or supplying a component to an EU manufacturer, will be asked for evidence of where its inputs came from. Building up stock before December 2027 does not help: the ban applies to products sold after that date, whenever they were made.

Where we come in

Meridian Intermediaries maps suppliers below the first tier, screens them for forced-labour risk, and assembles origin evidence that does not rest on audits alone. Each link is graded, so you know what will hold up when an authority or customer asks.

What to check

• Which products you sell into the EU, and which inputs come from regions or sectors with known forced-labour risk.
• Who made each input, by name, at the first tier and below.
• What evidence you hold, beyond supplier declarations and social audits. The guidelines say audits are not credible where forced labour is imposed by the state.
• How you would respond to an information request from an EU authority, and how quickly.