From 14 December 2027, under the EU Forced Labour Regulation, a product made with forced labour at any stage, from the cotton field to the sewing line, may not be sold in the European Union or exported from it. The ban covers goods on the EU market from that date even if they were made earlier, so yarn and fabric shipped this season can fall under it. When an authority’s first request for information reaches your buyer, the buyer has 30 working days to answer, and much of what it can be asked for is held by its suppliers.
This page sets out what Regulation (EU) 2024/3015 prohibits, how a case starts, who has to answer and how fast, what happens to the goods, and what the Commission has published so far. It then translates the rule into the records a spinner, fabric mill or garment exporter keeps on file, and marks which of them the Commission’s guidelines name and which are good practice only.
EU Forced Labour Regulation: the short version
- The ban: economic operators may not place or make available on the EU market, or export, any product made wholly or in part with forced labour at any stage of its extraction, harvest, production or manufacture (Regulation (EU) 2024/3015, Articles 2(7) and 3). It applies to products of any origin, including those made inside the EU (guidelines, section 3.1), and to companies of all sizes.
- From when: the Regulation entered into force on 13 December 2024 and applies from 14 December 2027 (Article 39).
- Who investigates a supplier abroad: the European Commission, whenever the suspected forced labour is outside the EU (Article 15).
- How fast an operator must answer: 30 working days to a preliminary request; 30 to 60 working days, as the authority sets, once an investigation is open (Articles 17 and 18).
- What happens to banned goods: withdrawal from the EU market and disposal, by recycling or, where that is not possible, by rendering them unusable (Articles 20 and 25).
- The guidelines were adopted on 26 June 2026 and published in the Official Journal on 3 September 2026. They list supply-chain maps, purchase orders and laboratory test results among the information an authority may request. The risk database the Regulation required by 14 June 2026 is still marked “in development” by the Commission.
Dates
| Date | What happens | Source |
|---|---|---|
| 27 Nov 2024 | Regulation (EU) 2024/3015 signed; published in the Official Journal on 12 December 2024 | OJ L 2024/3015 |
| 13 Dec 2024 | Entry into force. The Commission’s duties to build the risk database and write the guidelines, and the Member States’ duty to name their authorities, run from this day | Article 39 |
| 14 Dec 2025 | Member States tell the Commission which authorities will enforce the ban | Article 5(3) |
| 24 Apr 2026 | Implementing Regulation (EU) 2026/903 specifies the information system the authorities share | OJ L 2026/903 |
| 14 Jun 2026 | Legal deadline for the risk database and for the guidelines | Articles 8(3) and 11 |
| 26 Jun 2026 | Guidelines adopted as Commission Notice C(2026) 4386 | Guidelines |
| 30 Jun 2026 | Forced Labour Single Portal and preparedness package launched | Commission |
| 3 Sep 2026 | Guidelines published in the Official Journal as C/2026/4637 | OJ C/2026/4637 |
| 20 Oct 2026 | Commission webinar with a textile-sector focus: supply-chain visibility and supplier engagement | Commission |
| 14 Dec 2026 | Member States notify the Commission of their penalty rules | Article 37(3) |
| 14 Dec 2027 | The ban applies; the public point for reporting suspected cases opens | Article 39; Commission |
| 14 Dec 2029 | First Commission evaluation, then every five years | Article 38 |
How an investigation starts
The Commission and the national authorities work on a risk-based approach (Article 14). To decide which products to look at first, they weigh three things: the scale and severity of the suspected forced labour, including whether a state imposes it; the quantity of the product placed on the EU market; and the share of the suspect part in the final product. In a cotton yarn or fabric, the fibre is most of the product.
The assessment draws on the authorities’ shared information system (including an operator’s past cases), the Commission’s risk database, the risk indicators in the guidelines, reports submitted by anyone through the single submission point, information from other authorities such as labour and tax inspectorates, and consultation with civil society and trade unions. When the suspected forced labour is outside the EU, the Commission leads the case (Article 15). It is told to focus on the operators closest to where the forced labour is likely to be and with the most leverage to stop it, and to take into account an operator’s size, in particular whether it is an SME, and the complexity of the supply chain (Article 14(4)).
The Regulation’s duties fall on economic operators: whoever places products on the EU market, makes them available there, or exports them (Article 2(9)). A spinner or mill outside the EU that sells to an EU importer is usually a product supplier in the Regulation’s terms (Article 2(12)). The authority can still ask it for information directly (Article 17(1)), and the guidelines say this includes manufacturers higher up the chain with no direct link to the EU market (guidelines, section 4.5.2). More often the request will reach you through your buyer: for forced labour outside the EU, the guidelines say importers are likely to be the operators the authorities focus on (section 4.3.2). Inspections outside the EU are exceptional and need both the operators’ consent and a third-country government that has been notified and does not object (Article 19).
Who has to show what, and how fast
| Stage | What happens | Deadline | Article |
|---|---|---|---|
| Preliminary phase | The authority asks the operators, and where relevant other product suppliers, what they have done to identify, prevent, mitigate, end or remediate forced-labour risk for the products | Answer within 30 working days of receiving the request | 17(1)–(2) |
| End of the preliminary phase | The authority decides whether there is a “substantiated concern” | Within 30 working days of receiving the answers | 17(3) |
| Investigation opened | Operators are told the products concerned, the reasons (unless that would jeopardise the case) and the date for their submissions | Within 3 working days of the decision to investigate | 18(1) |
| Investigation | Operators submit information identifying the products, their manufacturer, producer and product suppliers | Set by the authority at 30 to 60 working days; an extension can be requested with reasons | 18(3)–(4) |
| Decision | Ban decision, or the case is closed | The authority aims for 9 months from opening | 20(1) |
| Compliance | Withdrawal and disposal orders are carried out | At least 30 working days | 22(1)(b) |
| Review | An operator asks for review, with new substantial information | Decided within 30 working days | 21(1)–(2) |
The authority carries the burden of proof: it must establish that forced labour was used and that the operators put the products on the EU market or exported them (recital 47; guidelines, section 4.8.1.1). That does not make silence safe. If an operator refuses to answer, misses a deadline without good reason, or gives incomplete or misleading information, the authority may decide on the other facts it has (Article 20(2)). The guidelines add that a complete lack of traceability information, where a product or raw material may have been mixed with one at high risk of forced labour, may weigh against the operator (section 4.8.1.1). For a mill buying cotton from several origins, that sentence is the reason to keep the records described below.
An SME under assessment can ask a national contact point for help in dealing with the authority (Articles 10 and 17(2)), and the Commission publishes the list of national authorities on its Forced Labour Regulation page.
What happens to the goods
If the authority finds a violation, its decision bans placing, making available and exporting the products concerned, orders the investigated operators to withdraw any already on the EU market (or take down online listings), and orders them to dispose of the products (Article 20(4)). Disposal follows the waste hierarchy: recycle, and only where that is not possible, render the product unusable (Article 25). Where the fault lies in a replaceable part, only that part is disposed of, and the product can return to the market with a compliant replacement. Goods that have already reached end users are not recalled (Article 1(2)).
Three consequences matter to a supplier. The decision identifies the product and gives details of its manufacturer, producer and product suppliers and, where appropriate, the production site (Article 22(1)(c)). Ban decisions are published on the Commission’s Forced Labour Single Portal (Article 12). And a decision by one Member State’s authority is recognised and enforced by the others for products with the same identification from the same supply chain (Article 20(8)).
At the border, customs suspend the release of goods that may be covered by a decision. If the authority confirms they are, customs refuse release or export, record the refusal and, where possible, mark it on the commercial invoice, and the goods are disposed of (Articles 28 to 30). A decision is withdrawn once the operators show they have complied and brought the forced labour in that supply chain to an end (Article 21(3)). Member States set the penalties for failing to comply with a decision (Article 37).
What the Commission had to publish, and what it has
| Item | What the Regulation asks for | Legal deadline | Status on 3 October 2026 |
|---|---|---|---|
| Database of forced-labour risk areas or products (Article 8) | Indicative, evidence-based information on risks by area, product or product group, including state-imposed forced labour, drawn from the ILO, the UN and research bodies. It may not publicly name companies | 14 June 2026 | Not yet published: the Commission’s database page reads “Database in development”, and its resources page calls it “currently under development” |
| Guidelines (Article 11) | Due-diligence guidance for operators, best practice on ending and remediating forced labour, guidance for authorities on risk benchmarks and the standard of evidence, risk indicators, and how to deal with the authorities | 14 June 2026 | Adopted 26 June 2026; published as C/2026/4637 on 3 September 2026. They cover every Article 11 item except customs guidance under Article 27, to be considered if and when delegated acts under that article are adopted |
| Forced Labour Single Portal (Article 12) | One public website for the authorities, guidelines, database, submission point and decisions | No separate deadline | Launched 30 June 2026 (Commission) |
| Single information submission point (Article 9) | Anyone can report a suspected violation, with evidence | Applies with the Regulation | Available from 14 December 2027 (Commission) |
The guidelines are guidance only; the Regulation alone has legal force. They describe the Regulation as an obligation of result that imposes no due-diligence duty, while treating due diligence as a useful way to comply, and they set out six steps, each referenced to the OECD’s due-diligence guidance: build it into policies, identify and assess risks, prevent and end them, monitor, communicate, and remediate (sections 1 and 6). Companies also covered by the EU’s due-diligence directive (CSDDD) are pointed to that directive’s rules (section 6). Section 4.7 lists examples of the information an authority may request, and those lists are the basis of the next section.
The evidence file, by document type
The Regulation itself names few documents. During an investigation it asks for information identifying the products and their manufacturer, producer, product suppliers, importer or exporter (Article 18(3)). The detail is in section 4.7 of the guidelines, which the Commission calls illustrative and non-exhaustive; it also warns that providing the information does not guarantee that a product will escape a ban. The table shows what the guidelines name. The last column shows what US Customs and Border Protection names for cotton and apparel under the UFLPA (Operational Guidance for Importers, June 2026, Appendices A and E), because many mills ship to both markets.
Named in the Regulation or its guidelines
| Document type | What the EU guidelines name | Where | What CBP names (US) |
|---|---|---|---|
| Fibre and yarn origin | Chain-of-custody certificates and raw-material traceability data; documents linking the finished product to its raw-material source; certificates of origin from the sites the products come from; bills of materials; affidavits from the operators involved in production | 4.7.3.1, 4.7.3.2 | Records showing the whole supply chain from the origin of the cotton at bale level to the finished product; certificates of origin or manufacturers’ affidavits |
| Purchase orders and transaction records | Purchase orders; invoices and receipts for all suppliers; packing lists; payment records; supplier and buyer inventory records, including warehouse receipts; shipping documents and bills of lading; import and export records | 4.7.3.4 | The same list, plus bills of materials |
| Production records | Production orders; factory capacity reports; evidence that input volumes match output volumes | 4.7.3.5 | Production orders, capacity reports, factory visit reports, input-to-output volume evidence |
| Supply-chain maps to the raw material | A description of the supply chain covering its key stages; supply-chain maps covering tiers and sub-tiers, direct and indirect suppliers; a list of manufacturers, producers and suppliers at each key step with name, trade name, contact details, national identification number and EU customs (EORI) number where one exists; ownership links and intermediaries; facility names and addresses, with geolocation where available | 4.7.3.2, 4.7.3.3 | A flow chart of the production process with numbered steps, maps of the region where each step happens, every company involved at each step, and the business record that identifies each upstream company the importer did not deal with directly |
| Audit and remediation records | Third-party independent audit reports; social audits; corrective action plans and performance evaluations; records of remediation, compensation and corrective measures. Social audits done where workers are under threat or constant surveillance, or where access is limited, are not considered credible | 4.7.1, 4.7.2, 4.8.1.1 | Audits that are unannounced, independent and assessed against the ILO indicators of forced labour; financial and environmental audits are not enough |
| Worker-voice and grievance records | Records showing a grievance mechanism exists, and its reports; worker interview transcripts and written testimonies; worker lists, contracts, payrolls and financial records; surveys by trade unions or worker representatives | 4.7.1, 4.7.2, 4.8.1.1 | Wage payment and output per worker, and how workers were recruited (for goods from China) |
| Laboratory origin tests | Laboratory test results, including isotopic testing | 4.7.3.1, 4.8.1.1 | Isotopic test reports are accepted as part of a review, with the sample’s chain of custody |
| Policies and supplier terms | Forced-labour policy and code of conduct; procurement policy; supplier code of conduct and contract clauses prohibiting forced labour; supplier onboarding and monitoring; training records | 4.7.1, 6.4.1 | A written supplier code of conduct, training for staff who deal with suppliers, and monitoring of supplier compliance (for an exception review) |
Laboratory origin tests: a tool, not a verdict
Origin testing appears in both regimes. The EU guidelines list laboratory results, including isotopic testing, among the evidence an authority may weigh (section 4.8.1.1). CBP uses isotopic testing to judge risk in suspect supply chains and to screen high-risk cargo, and encourages importers and manufacturers to build testing into their own due diligence early, because results take time (CBP isotopic testing guidance). For cotton, the test compares the fibre’s isotopic signature, set by the conditions where the plant grew, with a reference library, and can show only whether the sample is consistent with the origin claimed.
CBP is explicit about the limits. No ISO or ASTM standard method exists; each provider uses its own. Blends such as cotton/polyester need the cotton separated first, and not every blend can be tested. A test report is one piece of evidence, generally not enough on its own to release detained goods, and its result is treated as evidence, not fact. CBP suggests choosing a provider accredited to ISO/IEC 17025 (or working towards it) that follows the FIRMS Network’s good-practice guides, holds a reference library covering the growing regions in question, and can document the chain of custody of every sample.
Good practice: what makes the file usable (not named by any rule)
None of these is required by the Regulation, and none appears in the guidelines’ lists of information an authority may request. They are this page’s suggestions for turning the named records into a file that can answer a question about one shipment.
- File by lot and shipment, not by supplier. Carry one chain of references through every document: bale or fibre lot, yarn lot, fabric lot, purchase order, invoice, bill of lading. CBP accepts one test report for several shipments only when the importer shows the link, such as the same style and lot number, purchase order or contract (isotopic testing guidance).
- Start with current production. The Regulation sets no retention period, but the ban covers goods still on the EU market after 14 December 2027 even if they were made before it (guidelines, section 3.1). Agree a retention period with each EU buyer in writing.
- Record mixing as well as origin. Where cotton of different origins goes through the same blow room, keep the mixing or laydown records that show which bales went into which yarn lot. That answers the guidelines’ point about products that may have been mixed with high-risk material.
- Keep a retained sample of each cotton lot, sealed and labelled, with a note of who took it and when, so a test can be run later. CBP asks for the sample’s chain of custody from collection to the laboratory.
- Record the facts behind the risk indicators: whether any worker paid a recruitment fee, whether wages go to workers’ own accounts, who holds identity documents, and overtime hours. Debt, withheld wages and retained identity documents are among the indicators the guidelines list (section 3.4).
- Name one person who answers evidence requests and can hand over a shipment’s file well inside the buyer’s 30 working days, translated where needed.
- Use the free tools the Commission lists. Its resources page names facility and supply-chain tools, including Open Supply Hub and, for apparel, Supply Trace, without endorsing them.
How the EU rule differs from the US UFLPA
Many mills already keep a file for US buyers under the Uyghur Forced Labor Prevention Act (Public Law 117-78, approved 23 December 2021). The two rules start from opposite ends.
| EU Forced Labour Regulation | US UFLPA | |
|---|---|---|
| Applies from | 14 December 2027 | The rebuttable presumption took effect on 21 June 2022 (CBP) |
| Reach | Products of any origin on the EU market or exported from it, including EU-made goods | Goods imported into the United States |
| Starting point | A risk-based investigation of a particular product | A presumption that goods made wholly or in part in Xinjiang, or by an entity on the UFLPA Entity List, are barred from entry (section 3(a)) |
| Who must prove | The authority; an operator’s non-cooperation lets it decide on the other facts available | The importer: it must have fully complied with the importer guidance in the US UFLPA Strategy, answered every CBP request completely, and shown by clear and convincing evidence that no forced labour was used (section 3(b)) |
| Named companies | The risk database names none; a ban decision names the suppliers and production site concerned | The UFLPA Entity List names companies, including cotton traders, spinners, textile mills and garment makers, not all of them in Xinjiang. The Forced Labor Enforcement Task Force, chaired by the Department of Homeland Security, maintains it, and it is published in the Federal Register |
| Clock | 30 working days (preliminary request); 30 to 60 working days (investigation) | 30 days after a detention to export or destroy the goods, or to ask for a review (CBP guidance) |
| Outcome | Ban, withdrawal and disposal; the decision is published | Detention or exclusion at the US border |
The overlap in paperwork is large. CBP’s cotton list asks for records that trace the cotton from the bale to the finished product, a numbered flow chart with maps of where each step happens, and the business records that identify each upstream company. For an applicability review it lists purchase orders, invoices, packing lists, bills of materials, certificates of origin, payment, inventory and shipping records, production records and input-to-output volume evidence (Appendices A and E). Built carefully, one file answers both markets. The register holds both instruments: the EU Forced Labour Regulation and the UFLPA.
How this page is kept
Last verified: 3 October 2026. Built from the Official Journal text of Regulation (EU) 2024/3015, the Commission’s guidelines (C/2026/4637) and its Forced Labour Regulation pages, the enrolled text of Public Law 117-78, and the UFLPA pages and guidance of US Customs and Border Protection and the Department of Homeland Security, each linked where it is used. The dated records sit in the regulation register. This page describes what the instruments say; it is not legal advice for a particular product or shipment. Corrections are welcome through the contact page.
