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Subject: Joint civil society and trade union letter on the Forced Labour Portal and implementation guidance under Regulation (EU) 2024/3015, 2 September 2026
We, the undersigned organisations, welcome the publication on 26 June 2026 of the preparedness package including the Forced Labour Portal and the guidance, which sets out the implementation process and obligations for authorities and companies under Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market. We view this guidance as a key building block in the EU's broader forced labour architecture.
This framework provides a solid foundation that could be further strengthened by addressing the following:
The definition of forced labour and its indicators should be interpreted taking into account the social, economic and cultural context of the victim, reflecting the inherent case-specific nature of this exercise. Relatedly, we would caution against overreliance on the ILO forced labour indicators as a checklist to evaluate coercion and involuntariness. They should serve as a starting point for contextual analysis of how forced labour manifests and how it can genuinely be brought to an end, not as a substitute for it;
In terms of the investigation procedure, future guidelines should:
Clarify further the need to avoid overreliance on results of social audits submitted by economic operators during the investigative process to demonstrate absence of forced labour...
Emphasize the importance of triangulating information submitted by economic operators during the investigative process through a tailored process that takes into account the risk of false compliance or worker coercion.
Highlight that actions to identify, prevent and remediate forced labour must be appropriate and effective to be considered as relevant in mitigating and/or remediating forced labour.
Ensure that Member States and the European Commission receive explicit capacity-building support and adequate financial and human resources for effective enforcement, including for the provision of adequate accompanying measures to economic operators, in particular SMEs (Art. 10).
We regret however, that the portal does not yet include a full list of Member States' competent authorities, even though EU Member States were required to designate one or more competent authorities by 14 December 2025.
Additionally, it does not include more detailed “guidance for economic operators on best practices for bringing to an end and remediating different types of forced labour” (Art. 11.b) nor on “due diligence in relation to forced labour imposed by state authorities” (Art. 11.f).
ECCHR and Anti-Slavery International published an analysis of the EU Forced Labour Regulation, including an assessment and recommendations to support its implementation and enforcement.
The Council has adopted a regulation prohibiting products in the Union market that are made using forced labour. The text forbids the placing and making available on the Union market, or the export from the Union market, of any product made using forced labour.
The European Union has adopted the Forced Labor Regulation, which bans the sale of products made with forced labour. Hélène de Rengervé of Human Rights Watch argues that effective enforcement will require significantly increased capacity from the European Commission and EU member states.
The European Parliament has given its final approval to a new regulation enabling the EU to prohibit the sale, import, and export of goods made using forced labour (EP press release).
Lawmakers in the EU today voted in favour of a far-reaching law to ban products made with forced labour from the single market – a move welcomed by workers around the world (press release by Anti-Slavery International).
The preliminary endorsement by member states of the Forced Labour Regulation ramps up pressure on wavering countries to also endorse CSDDD on Friday, reducing the political room to justify continued resistance to the law.
The undersigned Civil Society Organisations and Trade Unions call on the governments of EU Member States to support the agreed text, ensuring the legislation enters into force without delay.
The Council and the European Parliament have reached a provisional deal on the regulation prohibiting in the EU market products made with forced labour.
Including remediation and other appropriate measures in the EU Forced Labour Regulation would enhance the legislation’s effectiveness in eradicating forced labour from supply chains, the statement says.
A letter, on behalf 33 civil society organisations and trade unions, to outline key issues that should be considered during the upcoming trilogues in order to make the proposed EU Forced Labour Regulation (FLR) a success.
On 26 January, the Council has adopted its position (negotiating mandate) on the regulation prohibiting products made with forced labour on the EU market.
This letter outlines four core elements that must be included: an evidentiary regime adapted to forced labour, provisions on state-imposed forced labour, one-stop shop EU-wide complaints mechanism, remediation.
This paper analyses the plans of the European Union for a forced labour ban that would prohibit the placing of products made with forced labour on the common market as well as the export of such products. It addresses concerns and provides recommendations for effective legislation following a human rights-based approach.
This week, the Internal Market and International Trade committees adopted their position on keeping products made using forced labour out of the EU market, IMCO, INTA.
As the negotiations on the content of the legislation advance, the undersigned Civil Society Organisations, Coalitions and Trade Unions, put forward key elements to make the proposed regulation efficient, implementable and impactful
Members of the European Parliament are proposing to extend the scope of a draft EU regulation prohibiting forced labour products from the EU market to key services and to introduce remediation for victims.
17 EU and international civil society organisations have written to the Spanish Presidency of the EU Council calling for swift progress towards a Forced Labour Regulation which provides remediation to workers who have experienced forced labour.
Investors shared a letter they submitted to the EU Commission and EU Parliament charged with the development of the EU’s Proposed Forced Labor Product Ban
Anti-Slavery International, the European Center for Constitutional Human Rights (ECCHR) and the Greens/EFA Group in the European Parliament commissioned research into a proposal on how an EU import ban should be designed to meaningfully address forced labour and keep workers at its heart
The statement calls on the European Parliament and EU Member States to improve the proposal where it is missing its purpose, whilst building on its key positive elements.
Though the proposal was broadly welcomed by both labor rights organizations and businesses, critics point to deficiencies — which might cut into its effectiveness.
EU lawmakers in the Parliament had called for such an instrument in June 2022, the Commission first announced plans for a new legislative instrument in February 2022.
On 9 June 2022, the European Parliament adopted a resolution calling for an import ban on products produced with forced labour from entering the EU market. The Parliament's recommendations, intended to feed into the EU Commission's ongoing drafting of new EU rules on products created or transported by forced labour, have been welcomed by civil society. However, the future instrument must put victims first and be remedy-centered, says the European Coalition for Corporate Justice (ECCJ).
The EU announces plans to promote decent work, and to prepare a new legislative instrument to ban products made by forced labour from entering the EU market
During the annual State of the EU speech, Ursula von der Leyen announced the block's intention to introduce a ban on the import of products made with forced labour
The Commission and the European External Action Service (EEAS) published a guidance document on due diligence to help EU companies to address the risk of forced labour in their operations
Consideration of import controls on forced labour products coincides with the forthcoming European Commission legislative proposal on Sustainable Corporate Governance. CSOs highlight key considerations relevant to the development and functioning of these two parallel policy processes.
Anti-Slavery International and European Center for Constitutional and Human Rights’ position on import controls to address forced labour in supply chains
New report commissioned by the European Parliament analyses EU options for introducing an import ban on products related to severe human rights violations
