EU Law for Suppliers

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

Short answer: The EU Forced Labour Regulation (EU) 2024/3015 bans products made wholly or partly with forced labour from being placed on, made available on, or exported from the EU market. It applies from 14 December 2027 to all products, of any origin and from any stage of the supply chain. It creates no new due-diligence duty, but authorities investigate on a risk basis, and documented supply-chain due diligence is the clearest way for a company to show its products are clean. The Commission published its guidelines on 26 June 2026.
বাংলায় সংক্ষেপে: ইইউ জবরদস্তিমূলক শ্রম আইন (Regulation (EU) 2024/3015) ১৪ ডিসেম্বর ২০২৭ থেকে কার্যকর। জবরদস্তিমূলক শ্রমে তৈরি কোনো পণ্য — পুরো বা আংশিক — ইইউ বাজারে বিক্রি বা ইইউ থেকে রপ্তানি করা যাবে না। এতে বাংলাদেশে তৈরি পোশাকও পড়ে। বায়াররা কারখানার কাছে নিয়োগ, মজুরি, কর্মঘণ্টা, সাব-কন্ট্রাক্টর আর সুতা/কাপড়ের উৎসের প্রমাণ চাইবে।
EU Forced Labour Regulation: key facts (as of 9 November 2026)
Detail
Legal actRegulation (EU) 2024/3015, published in the Official Journal on 12 December 2024
In force / appliesIn force 13 December 2024; the ban applies from 14 December 2027
What is bannedPlacing on or making available on the EU market, and exporting from the EU, products made with forced labour
ScopeAll products, all origins, any stage of production, including components and raw materials; no sector or country list
GuidelinesPublished 26 June 2026; Commission notice in the Official Journal on 3 September 2026
Risk databaseRequired by the Regulation; not yet available as of September 2026
PenaltiesMember States must notify their penalty rules by 14 December 2026
Who investigatesThe Commission for risks outside the EU; national competent authorities for risks inside the EU
The Ban

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.

Enforcement

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.

Guidelines

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.
At the Factory

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.
Link to the DPP

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.

EU Forced Labour Regulation FAQ

Quick Answers

When does the EU Forced Labour Regulation apply?
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From 14 December 2027. It entered into force on 13 December 2024; the Commission published guidelines on 26 June 2026, and Member States must notify their penalty rules by 14 December 2026.
Does it apply to garments made in Bangladesh?
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Yes. It covers all products placed on or made available on the EU market, whatever their origin, and products exported from the EU. No country or sector is singled out.
Is due diligence mandatory under the Regulation?
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No standalone due-diligence duty is created. The Commission's guidelines make clear, however, that documented due diligence is the clearest way to show compliance and reduce enforcement risk.
What happens to a product found to be made with forced labour?
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The company must withdraw it from the EU market and dispose of it, and it cannot be placed on the market or exported again. Penalties are set by Member States.
Is there an official list of high-risk countries or products?
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The Regulation requires the Commission to set up a database of forced-labour risk areas and products. As of September 2026 it was not yet available; it will not name individual companies.
Keep Reading

Go Deeper

Company due diligence vs product data.
Mapping Tier-1 and Tier-2 suppliers.
What brands write into vendor manuals.
Tariffs move; product rules don't.
Sources & official references
DPPLive’s Take

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.

For garment factories

Make your first Digital Product Passport this week

Start with a free four-week pilot on one style. After that DPPLive is free for up to 10 passports a month; above 10 a month we agree a custom price with you.

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