EU Forced Labour Regulation: What Garment Suppliers Need to Know
Regulation (EU) 2024/3015 bans products made with forced labour from the EU market. It names no country and no sector, so every garment sold in the EU is covered — including those made in Bangladesh.
Written by the DPPLive Team · Last updated: 9 November 2026
| Detail | |
|---|---|
| Legal act | Regulation (EU) 2024/3015, published in the Official Journal on 12 December 2024 |
| In force / applies | In force 13 December 2024; the ban applies from 14 December 2027 |
| What is banned | Placing on or making available on the EU market, and exporting from the EU, products made with forced labour |
| Scope | All products, all origins, any stage of production, including components and raw materials; no sector or country list |
| Guidelines | Published 26 June 2026; Commission notice in the Official Journal on 3 September 2026 |
| Risk database | Required by the Regulation; not yet available as of September 2026 |
| Penalties | Member States must notify their penalty rules by 14 December 2026 |
| Who investigates | The Commission for risks outside the EU; national competent authorities for risks inside the EU |
What the Regulation Prohibits
The Regulation uses the ILO definition of forced labour: work or service exacted under threat of a penalty and not offered voluntarily, including forced child labour. A product is caught if forced labour was used at any stage — cotton farming, spinning, weaving, dyeing, sewing or packing.
It applies to products placed or made available on the EU market from 14 December 2027, including stock produced or imported before that date. Violating the ban does not require that the company knew about the forced labour.
How Investigations Work
Authorities follow a risk-based approach, using the severity and scale of suspected forced labour, the quantity of products involved and the Commission's risk information. The process has a preliminary phase, in which the company is asked for information, then a formal investigation if there is a substantiated concern, and a final decision.
If a violation is confirmed, the products must be withdrawn from the EU market and disposed of, and they may not be placed on the market again. Outside the EU, the Commission can inspect a site only with the consent of the company and the host country. From 14 December 2027 anyone can submit information through the Single Information Submission Point.
What the Commission Guidelines Say
- The Regulation does not impose a standalone due-diligence obligation.
- Due diligence aligned with OECD guidance remains the strongest evidence a company can bring in an investigation.
- Cooperation matters: companies are expected to answer information requests fully and on time.
- The ban covers products, not services.
What EU Buyers Will Ask Garment Factories
EU brands and importers carry the legal risk, so they will ask suppliers for evidence. Expect requests for:
- recruitment records showing no recruitment fees charged to workers and no retained identity documents;
- wage, working-hour and overtime records;
- a full list of subcontractors and processing units, disclosed in advance;
- the origin of cotton, yarn and fabric, with Tier-2 suppliers named;
- recent social audit reports and the corrective-action plans that followed.
Forced Labour Checks and the Digital Product Passport
The Regulation does not require a Digital Product Passport, and a passport does not prove that a product is free of forced labour. They share a data layer: the supplier and origin records a factory keeps for a DPP — which mill, which spinner, which country — are the same records an importer needs to answer a forced-labour information request. One clean data pipeline serves both.
Quick Answers
Go Deeper
- Regulation (EU) 2024/3015 — full text on EUR-Lex
- European Parliament Legislative Observatory — summary of Regulation (EU) 2024/3015 — entry into force and application dates
- Baker McKenzie — EU publishes guidelines on the Forced Labour Regulation — 26 June 2026 guidelines
- Osborne Clarke — Regulatory Outlook, September 2026 — OJ notice 3 September 2026; risk database not yet available
Evidence Beats Assurances
A letter saying “no forced labour” will not answer an EU information request. Records will: who was recruited and how, what they were paid, who made the fabric. Factories that keep those records per style keep their buyers.