Regulation 2024/3015: the prohibition applies from 14 December 2027. The chain has to be knowable before then.
A ban can keep a product off the market. It cannot tell an organisation which supplier, which batch or which piece of evidence will be asked for first.
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 is the operating test
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 by itself prescribe a single questionnaire. In practice, an operator that cannot reconstruct the chain, locate 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.
The risk is not only a prohibition decision. It is reaching an information request without a map of suppliers, a view of country and product risk, or a file that explains what was asked, found and done.
Where readiness 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.
These are connected decisions. A supplier list without risk scoring, or a policy without an investigation workflow, leaves the organisation to assemble a defence under a 30-working-day clock.
What Ontzi builds
Ontzi turns the prohibition into an investigation-ready operating model. We connect supplier intelligence to country and product risk, make questionnaires and evidence retrievable against the goods in question, and give investigations a path from alert to documented response.
The immediate output is the ability to answer. The durable value is a repeatable capability: the organisation knows where exposure sits, what evidence exists, who owns the next action and how to show it.
The ban is the rule. The operating model is what makes a response defensible.
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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.