The ban on products made with forced labour
Any product made with forced labour, at any tier, may not be sold in or exported from the EU. Every operator, no size threshold, enforced by investigation.
Regulation (EU) 2024/3015, Articles 3, 8, 17 and 20
In force since December 2024. Applies from December 2027. Commission guidelines June 2026; national penalty rules by December 2026.
The Forced Labour Regulation bans any product made wholly or partly with forced labour from the EU market, whoever made it and however small the company that sells it. It entered into force in December 2024 and applies from December 2027. It is enforced by investigation: an authority asks, the brand answers with what it knows about its supply chain, and a product can be withdrawn.
How enforcement works
- The Commission was due to publish an indicative database of areas and sectors with a forced labour risk by June 2026. It is meant as a starting point for authorities, not a list of banned origins.
- An authority with a substantiated concern opens a preliminary phase and asks the operator for information: what the supply chain looks like and what the company did to identify and address the risk. The operator has 30 working days to answer.
- If the concern holds, a formal investigation follows, with inspections and document requests. An operator that stays silent or answers in part can be judged on the facts the authority already has.
- A decision bans the product, orders its withdrawal and its disposal. It is recognised in every Member State for products with the same identification from the same supply chain, so one finding reaches identical goods everywhere.
What the rule asks of a brand
- An obligation of result: do not place a product made with forced labour on the market. The regulation sets no due diligence duty of its own.
- Due diligence is still what an authority asks about. The Commission's guidelines describe a documented system aligned with international standards as the expected answer to an information request.
- The information requested is concrete: suppliers by tier, the facilities involved, the origin of materials, and the actions taken when a risk was known.
- Member States set their own penalties for ignoring a decision, with rules notified by December 2026.
The regulation sets no passport field. But a passport names the countries, the facilities and the fibre origins behind a garment, which is what an information request asks for and what an authority can hold against its database. A brand whose passports are accurate has already written most of its answer.
Where brands get caught
- Knowing the sewing factory and nothing behind it. Fibre and fabric origin are where the risk sits and where the questions go.
- A shared supplier. A decision attaches to products with the same identification from the same supply chain, so another brand's finding can reach yours.
- Silence. Missing the deadline or answering in part lets the authority decide on what it has.
What to prepare this season
- Record the supply chain per style by tier, with the country and facility of each step, down to the fibre where you can.
- Keep certificates of origin and chain-of-custody documents attached to the suppliers and fibres they cover.
- Write down what you did when a risk came up: the question asked, the answer, the decision taken.
One record
What the Seamdex record already carries
- The supply chain per style by tier, with the country and facility of each step and the fibre origin behind the composition, shown on the passport in full or by country only.
- Certificates attached to the suppliers and fibres they cover, with validity dates tracked.
- A frozen snapshot per published size, so what a brand declared about a season stays retrievable.
The record carries the product data a report or an answer to an authority rests on. Not a compliance claim: reporting and due diligence duties sit with the company.
FAQ
Questions on this rule
Sources
- Regulation (EU) 2024/3015 (EUR-Lex) checked October 2026
- Commission guidelines on applying the forced labour regulation, Official Journal C (EUR-Lex, September 2026) checked October 2026
Related rules
Regulatory dates last reviewed October 2026. Future dates are expectations, not law. This guide describes the rules; it is not legal advice.
