Any day now, the European Commission is expected to publish two tools that will shape how the EU Forced Labour Regulation (EUFL) is enforced: compliance guidelines for businesses, and a risk database identifying high-risk geographic areas and product categories. 

The guidelines and database should clarify what's expected of companies and help identify where forced labour risk and regulatory scrutiny is likely to be greatest.

The regulation enters full enforcement on 14 December 2027. Companies selling goods into the EU that have a credible due diligence programme in place by then will be at a clear advantage when enforcement begins. 

ETI has published a set of new pages on forced labour and modern slavery, covering definitions, legislation, sector risk, migrant worker vulnerability, remediation, and the EUFLR itself. This post signposts the new pages and summarises what companies should be doing now, ahead of December 2027.

Why this moment is different

The EUFLR is not another reporting obligation. It is a product ban. Goods made with forced labour, anywhere in the world and at any stage of production, can be prohibited from the EU market, withdrawn, and destroyed at the operator’s expense. There’s no minimum company size, turnover threshold, or sectoral exemption.

This makes it fundamentally different from the UK Modern Slavery Act’s disclosure requirement or the CSDDD’s due diligence obligations. Those frameworks ask what you are doing about forced labour risk. The EUFLR asks a starker question: were the products you are selling made with forced labour? If an investigation concludes that they were, the product can be taken off the market.

The regulation was approved in December 2024, and the enforcement infrastructure is being built now: competent authorities in each EU member state, the Forced Labour Single Portal, and the investigation process. The forthcoming guidelines will clarify what “appropriate due diligence” should look like. The risk database will flag geographic areas, sectors and products where forced labour risk is high. Once a sourcing region or product appears in it, companies can realistically no longer credibly claim unawareness. This will likely drive pressure from investors, customers, and procurement bodies to show that exposure has been assessed.

Why forced labour is harder to address than most companies assume

The approaches most companies have used to manage forced labour risk, such as annual statements, periodic audits, and code of conduct sign-offs, are rarely designed to detect the exploitation the EUFLR and related legislation target. Forced labour concentrates where visibility is lowest, such as in informal supply chain tiers, among subcontractors and labour agencies, and among migrant workers who arrived in debt bondage before reaching any auditable worksite. Standard social audits, conducted with the employer’s cooperation, are often poorly suited to surfacing coercion or deceptive recruitment.

This is why the EUFLR, the updated UK Home Office guidance from March 2025, and the CSDDD all push toward due diligence that is ongoing, evidence-based, worker-centred, and built into commercial decisions. The companies best placed for EUFLR enforcement won’t be those with the most polished statements, but those that can show how they identified risk and what they did about it.

ETI’s forced labour and modern slavery guidance

Drawing on nearly 30 years of experience, including our role in shaping the UK Modern Slavery Act 2015, and our tripartite model, our new guidance pages cover:

Forced labour & modern slavery: a complete guide for business
What forced labour is, why it’s hard to detect, the legislative landscape, and what effective action involves.

What is modern slavery? Definitions, forms and scale 
How forced labour, modern slavery, and trafficking differ, plus the ILO’s eleven indicators.

How to identify forced labour in your supply chain 
The eleven indicators in practice, why standard audits miss serious exploitation, and what works better.

Modern slavery legislation: what businesses need to know 
The UK Modern Slavery Act, EU CSDDD, EUFLR, UFLPA, and laws in Canada, Australia, and Germany.

High-risk sectors and sourcing regions for forced labour
Where risk concentrates and why, across agriculture, garments, electronics, construction, and services.

Forced labour and migrant workers in supply chains
Migrant worker vulnerabilities, recruitment fees, debt bondage, the Kafala system, and the Employer Pays Principle.

How to write a modern slavery statement
Producing a statement that demonstrates real action, covering all six recommended areas and ETI’s Evaluation Framework.

Remediation: what to do when forced labour is found
Why immediate disengagement is rarely right, and what worker-centred remediation looks like.

EU Forced Labour Regulation: what it means for your business
How the EUFLR works, the investigation process, the risk database and Single Portal, and how to prepare.

What companies should be doing now

Map your supply chain beyond Tier 1. The EUFLR applies at every stage of production, and a product assembled in a low-risk country may contain high-risk inputs.

Assess your labour recruitment practices. Recruitment fees, debt bondage, and document retention are established during recruitment, before workers reach any auditable site.

Build CSDDD-aligned due diligence now. The EUFLR guidelines will align with CSDDD, so companies already working to that standard won’t start from scratch.

Review your modern slavery statement against the March 2025 UK guidance, which shifts emphasis toward evidence of outcomes. ETI’s Evaluation Framework offers a practical self-assessment tool.

Frequently asked questions

What does the EUFLR require businesses to do? It prohibits products made with forced labour from being placed on or exported from the EU market. Businesses need to show, if investigated, that their products weren’t made with forced labour. The Commission’s guidelines will define appropriate due diligence; until then, CSDDD-aligned due diligence is the best benchmark.

When does the EUFLR come into force? Enforcement will be from 14 December 2027. The infrastructure, including competent authorities, the Single Portal, and the risk database, is being established now.

How is the EUFLR different from the UK Modern Slavery Act? The UK Act requires an annual disclosure statement. The EUFLR is a product ban: goods made with forced labour can be prohibited, withdrawn, and destroyed. It applies to all companies selling into the EU regardless of size, and the consequence is removal of the product, not a reporting penalty.

What should companies do now? Map your supply chain beyond direct suppliers, assess labour recruitment practices, build CSDDD-aligned due diligence, and review your modern slavery statement against the March 2025 UK guidance. Once the risk database is published, check your supply chain against it.

Watch this space

The Commission’s compliance guidelines and risk database are due imminently. We’ll follow up with what they say and what companies should do next.

If your company wants support beyond reading guidance, including practical tools, peer learning, and collaborative programmes in high-risk sourcing regions, ETI membership is the next step.

Find out about ETI membership

Page

Forced labour & modern slavery: a complete guide for business

What forced labour and modern slavery mean in practice, why the regulatory environment is intensifying, what businesses are now expected to do – and how to build an approach that goes beyond compliance.

Read more

Page

Human rights due diligence (HRDD): a complete guide for business

The process of Human rights due diligence (HRDD) is the most practical and credible way for businesses to manage their human rights impacts on an ongoing basis. It is a critical cornerstone to the implementation of the UN Guiding Principles on Business and Human Rights (UNGPs).

Read more