We joined voices with trade unions and human rights organisations, including our member Anti-Slavery International, to welcome the publication, on 26 June 2026, of the EU Forced Labour Regulation preparedness package. The package, which includes the Forced Labour Portal and accompanying guidance, sets out the implementation process and obligations for authorities and companies under Regulation (EU) 2024/3015 on prohibiting products made with forced labour from the Union market. It represents a key step in combating forced labour and its publication is a positive development, though the guidance still leaves room for further strengthening.
We particularly welcome several aspects of the guidance. It offers a clear definition of forced labour centred on involuntariness and coercion, along with a clarification of scope that covers extraction, harvesting, production, and manufacturing. It further recognises the need to protect workers and petitioners throughout the investigation process, including through confidentiality, and takes into account a broad range of evidence types. The guidance also allows flexibility in submission requirements, reflecting the real challenges of gathering evidence of forced labour, and allows for a tailored evidentiary threshold that accounts for the complexity of documenting different types of forced labour cases. It further shows awareness of the particular constraints involved in documenting State-imposed forced labour, adapting the investigation and evidentiary threshold accordingly, and recognises that non-cooperation by economic operators is, in principle, relevant evidence in itself. Finally, on evidentiary standards, we welcome the exclusion of social audits conducted where workers are under threat, inducement or subject to surveillance by management.
This framework provides a solid foundation that could be further strengthened by addressing the definition of forced labour and its indicators should be interpreted taking into account the social, economic and cultural context of the victim, reflecting the inherent case-specific nature of this exercise. Relatedly, we would caution against overreliance on the ILO forced labour indicators as a checklist to evaluate coercion and involuntariness. They should serve as a starting point for contextual analysis of how forced labour manifests and how it can genuinely be brought to an end, not as a substitute for it;
In terms of the investigation procedure, future guidelines should:
- Clarify further the need to avoid overreliance on results of social audits submitted by economic operators during the investigative process to demonstrate absence of forced labour. Provide additional guidance to regulators to scrutinize audit quality, including but not limited to audits’ scope, methodology, disclaimers and use of stock phrases by audit firms.
- Emphasize the importance of triangulating information submitted by economic operators during the investigative process through a tailored process that takes into account the risk of false compliance or worker coercion.
- Highlight that actions to identify, prevent and remediate forced labour must be appropriate and effective to be considered as relevant in mitigating and/or remediating forced labour.
- Ensure that Member States and the European Commission receive explicit capacity-building support and adequate financial and human resources for effective enforcement, including for the provision of adequate accompanying measures to economic operators, in particular SMEs (Art. 10).
We also encourage all Member States to designate competent authorities without delay, so that the investigative mechanisms and structures needed for enforcement are in place and operational once the regulation becomes applicable.