Supplier & Contractor Management
People in forced labour globally (ILO, 2024)
No sector, origin, or size exemption
Full enforcement begins—product bans start
The EU Forced Labour Regulation is the EU's first product-based prohibition on forced labour goods. For supply chain teams, the core obligation is proving that no stage of your product's supply chain—from raw material extraction to final assembly—involves forced labour as defined by ILO Convention No. 29.
The Regulation applies to all products placed on, made available on, or exported from the EU market. There is no SME exemption. The European Commission will maintain a risk database identifying high-risk sectors, geographic areas, and product groups. Authorities will conduct risk-based investigations and can order product bans, market withdrawals, and disposal.
Forced labour compliance requires supply chain traceability and supplier-level due diligence evidence—origin data, labour attestations, and audit records—from every tier. When authorities investigate, your evidence is your only defence.
Key Components / Sub-Frameworks
Any economic operator placing products on the EU market
Importers bringing products into the EU for the first time
Distributors making products available on the EU market
Non-EU companies selling to EU importers or through EU channels
Companies assembling complex products from multi-tier supply chains
Online sellers targeting EU consumers via distance sales
Key Thresholds
The Regulation covers every stage—extraction, harvesting, manufacturing, and processing. Your product has 300 components sourced from 15 countries. You need forced labour risk assessments for each supplier, each origin, each tier. Your procurement team has labour attestations from fewer than 20% of Tier 2 suppliers.
An authority launches a preliminary assessment based on a risk database flag. You are asked to provide supply chain documentation—origin data, labour policies, audit records, supplier attestations—within a prescribed time period. Your evidence is scattered across procurement files, CSR reports, and supplier emails. Incomplete responses trigger a formal investigation.
Unlike chemical regulations with percentage thresholds, the Forced Labour Regulation has no de minimis exemption. A single component—even a minor input at Tier 4—made with forced labour triggers the full product ban. Without multi-tier traceability, you cannot prove your product is clean.
Authorities assess due diligence quality when deciding whether to investigate. Companies with documented, systematic processes may avoid formal investigations entirely. But assembling forced labour evidence across hundreds of suppliers, multiple geographies, and evolving risk indicators manually is unsustainable at enterprise scale.
Certivo In Action
EU Forced Labour Regulation Workflow
Electronics Manufacturing
Pain Point
Complex mineral supply chains; high-risk extraction geographies; deep sub-tiers
Automotive Manufacturing
Pain Point
Multi-tier global supply chains; raw material exposure; OEM flowdown requirements
Industrial & Heavy Equipment
Pain Point
Global sourcing; legacy supplier relationships; limited sub-tier visibility
Aerospace & Defense
Pain Point
Stringent prime flowdown; critical mineral sourcing; defense procurement rules
Consumer Goods
Pain Point
High SKU counts; agricultural inputs; seasonal supply chains; brand risk
Construction Materials
Pain Point
Raw material extraction risks; diverse global inputs; project-level compliance
Chemical Manufacturing
Pain Point
Feedstock sourcing from high-risk regions; complex intermediary chains
Energy & Infrastructure
Pain Point
Critical mineral dependencies; solar supply chain risks; long procurement cycles
80% Reduction in Compliance Labor
CORA collects and parses supplier labour attestations and origin data automatically. Your team focuses on risk exceptions that need human judgment—not manual evidence compilation.
4 Hours to Investigation Response
Generate complete, investigation-ready evidence packages in hours—not the weeks of manual compilation across procurement files and supplier emails.
Real-Time Risk Database Sync
When the Commission updates risk indicators or high-risk designations, Certivo reassesses your portfolio instantly. Know which supply chains are affected before authorities investigate.
Key Statistics
Frequently Asked Questions
What products are covered by the EU Forced Labour Regulation?
All products placed on, made available on, or exported from the EU market are covered—regardless of sector, origin, or company size. The ban applies to products and their components if forced labour was used at any stage of the supply chain, including extraction, harvesting, manufacturing, and processing. Certivo helps companies map their product portfolios against the Commission's risk database to identify exposure.
What are the penalties for non-compliance with the Forced Labour Regulation?
Authorities can ban products from the EU market, order their withdrawal, and require disposal at the company's expense. Member States will establish financial penalties that must be "effective, proportionate and dissuasive"—penalty frameworks are due by December 2026. Refusing to cooperate with investigations or providing misleading information can trigger adverse enforcement decisions.
Does the Forced Labour Regulation require companies to conduct due diligence?
The Regulation does not formally impose new due diligence obligations beyond existing EU and national law. However, authorities consider due diligence quality when deciding whether to investigate. Companies with documented, systematic due diligence may avoid formal investigations. CORA automates the collection and validation of supplier-level evidence that demonstrates proactive risk management.
How does Certivo help companies prepare for Forced Labour Regulation investigations?
Certivo collects forced labour attestations, origin declarations, and social audit evidence from every supplier tier. CORA validates this evidence against Commission risk indicators and ILO forced labour factors. When authorities request information, Certivo generates investigation-ready evidence packages—with full supply chain traceability—in hours instead of weeks.
How does the EU Forced Labour Regulation relate to the US UFLPA and CSDDD?
The Forced Labour Regulation complements CSDDD due diligence obligations with product-level enforcement. It operates similarly to the US UFLPA but without a geographic rebuttable presumption—any forced labour at any origin triggers the ban. Certivo validates supplier evidence against all three frameworks simultaneously, eliminating duplicate collection campaigns across jurisdictions.