BRUSSELS — Companies selling into the European Union now have practical guidance for a ban that will remove products made with forced labour from the market beginning on 14 December 2027.
The Forced Labour Regulation covers goods made inside or outside the EU and applies across sectors and company sizes. Authorities will be able to investigate suspected forced labour and order offending products withdrawn, withheld at customs or disposed of.
The European Commission’s portal says 27.6 million people worldwide are in forced labour. Women and girls are exposed through domestic work, agriculture, garment production, sexual exploitation and migration systems that tie legal status to an employer. Their work often sits several subcontracting layers below the brand whose name appears on a product.
Human Rights Watch said on 14 September that the guidance is an important step but needs strengthening. Its central concern is that compliance cannot rely mainly on corporate social audits. Workers and local civil-society groups must be able to submit evidence safely, participate in investigations and obtain remedy when a product ban confirms abuse.
That critique reflects a structural problem. An announced factory visit may measure whether paperwork exists while missing recruitment debt, confiscated passports, threats against migrant workers or production targets that force excessive overtime. Reuters reported earlier this month that the global social-auditing industry has grown even as voluntary due diligence has failed to eliminate forced labour.
The EU system offers leverage because access to a large market is valuable. But enforcement could also harm workers if a brand abruptly cancels orders and leaves wages unpaid. Investigators should therefore distinguish ending forced labour from abandoning a workforce. Remediation plans need repayment of recruitment fees, return of documents, wage recovery and protection against retaliation.
Transparency will determine credibility. The Commission and national authorities should publish the allegations assessed, reasons for opening or declining cases, products blocked and remedies obtained, while protecting survivors’ identities. Companies should disclose purchasing practices as well as supplier codes, because unrealistically low prices and short deadlines can create the conditions for coercion.
For women workers, the regulation’s success will not be measured by the number of compliance dashboards created in European headquarters. It will be measured at recruitment offices, farms, homes and factories: whether a worker can refuse overtime, leave an employer, keep her documents, report abuse and recover what she is owed.
The guidance starts the implementation period. The next 15 months must turn it into investigative capacity and worker-centred enforcement before the ban becomes legally applicable.
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