Regulation 2024/3015: the prohibition applies from 14 December 2027. A preliminary information request can land with 30 working days to reply.
Regulation (EU) 2024/3015 prohibits economic operators from placing or making available on the Union market — or exporting from it — products made wholly or in part with forced labour. The rule covers every sector, origin and sales channel, including distance and online offers aimed at EU end users. It applies from 14 December 2027.
This is a prohibition with consequences, not a reporting form. If a competent authority finds forced labour in a product, it can ban placing, sale and export, and order withdrawal and disposal. Customs can suspend release at the border. There is no size threshold and no safe harbour in a due-diligence certificate.
The investigation clock
Authorities work on a risk-based model: product volumes, severity, how close the operator sits to the suspected source, and the complexity of the chain. A preliminary phase can require information on prevention, mitigation and remediation, generally within 30 working days. A formal investigation can demand more, with 30 to 60 working days to respond, and should conclude within a reasonable period — nine months where possible.
The Commission investigates suspected forced labour outside the EU. Member State authorities investigate cases on their territory. A public risk database of products, product groups and geographies is meant to help both authorities and operators see where exposure concentrates.
The Regulation does not replace other due-diligence laws, and it does not prescribe a single questionnaire. An operator that cannot reconstruct the chain, find the relevant evidence or show what it did when a risk appeared will struggle to answer in time. Incomplete answers can weigh against the operator.
Where it breaks
- Chain: which suppliers, sites and product parts are in scope — including deeper tiers, where forced labour is more likely to sit.
- Evidence: questionnaires, certifications, audits, worker-voice signals and source documents that can be retrieved against a specific product, not stored as a general ESG archive.
- Response: who triages an authority request, who decides on containment or withdrawal, and how the rationale remains traceable after the deadline to reply.
What we build
We keep a supplier map scored by country and product risk, evidence that can be pulled for the goods in question, and a path from alert to a documented response: what was asked, found and done.
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This field note is general information, not legal advice. Scope, dates, penalties and investigation practice should be checked in the law applicable to each operator.