Updated: February 2026
This is part two in our EUFLR blog series, the first post can be found here.
The EU Forced Labor Regulation(EUFLR) entered into force in December 2024 and will start to apply from 14 December 2027. From that date, authorities can begin investigating products and taking action if forced labor is found in supply chains.
The regulation will then:
- Ban the placing and making available of products on the EU market, and exporting products, if they are made with forced labor.
- Apply to any company that places products on the EU market or exports from it, regardless of size, industry, or location.
- Apply to products wholly or partially made with forced labor.
Did you know?
If forced labor is found at any stage in the production of a product, the product can be withdrawn or removed from the market, disposed of, or prevented from being sold in the EU.
What is forced labor?
Forced labor is a form of modern slavery. It includes situations where people are exploited and cannot leave the job or workplace because of coercion, debt, threats, or deception. The International Labour Organization (ILO) defines forced labor as: “All work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily”.
27.6 million people were in forced labor worldwide in 2021, including 3.9 million in state-imposed forced labor.
Source: ILO, 2021 estimate.
To understand how forced labor can be identified in practice, read the ILO’s guide ILO Indicators of Forced Labor, published in November 2025. It presents 11 indicators of forced labor, including a new chapter on state-imposed forced labor.
Are forced labor and child labor the same?
Child labor and forced labor are not the same, but when children are forced to work through threats, coercion, or debt, it becomes forced child labor and falls under the EUFLR.
Why are many companies overlooking the EUFLR?
For a long time, the spotlight has been on the Corporate Sustainability Due Diligence Directive (CSDDD) and the Corporate Sustainability Reporting Directive (CSRD).
That focus has only intensified with the uncertainty surrounding the EU Omnibus I discussions. As a result, the EU Forced Labor Regulation (EUFLR) has received less attention.
Timing matters too, EUFLR will apply from 14 December 2027. Together, these factors have pushed EUFLR down the priority list for many companies, despite the regulation being an important part of the EU’s wider effort to strengthen supply chain transparency.
Is EUFLR affected by the EU Omnibus?
No. The EU Omnibus I package has changed parts of both the CSRD and the CSDDD (including timelines and scope), but it has not affected the EUFLR.
The EUFLR was not included in the EU Omnibus I package and has not been affected in the same way as the CSDDD and the CSRD.
How can companies prepare for EUFLR?
Risk-based due diligence at the core of the EUFLR
The EUFLR builds on a risk-based approach. This means companies need to explain how they identify, assess, and address actual (and potential) adverse impacts of forced labor in their operations and supply chains.
Effective supply chain due diligence processes are therefore an important preparation. They enable systematic risk management and documentation of efforts, helping authorities assess whether appropriate measures have been taken.
The EUFLR is not a new, standalone due diligence regulation alongside other responsible business conduct (RBC) directives and laws, such as the CSDDD, the Norwegian Transparency Act, and the German Supply Chain Act. Instead, it complements them.
Many RBC frameworks refer to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (the OECD Guidelines), which are widely used as a benchmark for effective due diligence and a helpful starting point for companies preparing for the EUFLR.
The OECD Guidelines set out a six-step process for effective due diligence:
- Embedding RBC into policies and management systems.
- Identifying and assessing adverse impacts in operations and supply chains.
- Ceasing, preventing, or mitigating adverse impacts.
- Tracking implementation and results.
- Communicating how impacts are addressed.
- Providing for or cooperating in remediation when appropriate.
Why is it important to start now?
Although 14 December 2027 may seem far away, building an effective due diligence process takes time. Mapping your supply chain, engaging suppliers, and gathering the necessary information should be done before the regulation takes effect.
Starting now helps avoid last-minute pressure and errors.
Read more here on how to use the Worldfavor platform to get this started efficiently.
How to get started with EUFLR
A data-driven due diligence process makes both implementation and follow-up with suppliers more effective. Makes sense, right? Built on deep sustainability expertise, our platform is designed to support companies with exactly this.
With the Worldfavor platform and its ready-to-use due diligence process, you can:
- Engage suppliers in 100+ languages to improve response rates and strengthen collaboration across your supply chain.
- Identify potential adverse impacts related to forced labor across your supply chain using our Modern Slavery Risk Index.
- Screen suppliers for actual and potential adverse impacts related to forced labor using our automated Forced Labor assessment, or create your own assessment by selecting KPIs from our Sustainability Data Library with 1,500+ ready-to-use KPIs.
- Communicate results effectively to internal and external stakeholders using built-in reporting features.
Talk to a Worldfavor expert today to learn how our platform can help your business align with EUFLR.
Under the EUFLR companies don’t need to produce additional reports on top of the ones that the companies are already producing. What a relief, we know.
But the results of the company’s due diligence efforts regarding forced labor should be included in the sustainability report that the company is publishing, whether it is under the Corporate Sustainability Reporting Directive, or not.
Psst… For a detailed breakdown of the EUFLR, don’t forget to read our blog post: The EU Forced Labor regulation (EUFLR): What you need to know.
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