Forced Labour Regulation (FLR)
The EU Forced Labour Regulation (FLR) prohibits businesses from marketing products within the European Union (EU) that are made using forced labour, including forced child labour. It also prohibits exporting such products from the EU. This legislation applies to all businesses, regardless of the sector or origin of the products. To be well-prepared, consider taking taking the necessary steps for due diligence steps.
What does the FLR entail?
Forced labour means "all work or services that an individual performs under the threat of a penalty and for which the individual has not offered themselves voluntarily". The FLR aims to combat forced labour and addresses unfair competition, as some businesses, unfortunately, continue to use forced labour as part of their operational model.
Who is subject to the FLR?
The FLR applies to all products, businesses and economic sectors. It also includes products sold through e-commerce platforms. But, the FLR does not include services.
How does the FLR work?
Where there is a suspicion that products were made with forced labour, the location where the forced labour took place or is taking place designates a lead competent authority. This authority investigates cases of forced labour:
- Outside the EU
The European Commission is the competent authority for the FLR on investigations and decision-making for products made using forced labour outside the EU.
- Inside the EU
Each Member State appoints competent authorities for conducting investigations and making decisions. Also, each EU Member State must appoint a competent authority for removing products from the EU market.
A decision has yet to be made about the competent authorities for the Netherlands. At the border, the Netherlands customs (Douane) will have a role in intercepting products made with forced labour.
The competent authority starts a risk-based investigation using the following assessment criteria:
- The scale and severity of the suspected forced labour;
- The quantity or volume of products placed on or made available in the EU market;
- The proportion of parts made with forced labour in a final product;
- The proximity of economic operators within their supply chains to the point of the suspected forced labour and the leverage they have to end or reduce the use of forced labour.
During the investigation phase, businesses must comply with requests from by the lead competent authority. For example, the authority may ask a business to show how it implements due diligence concerning forced labour. Based on the information given, the competent authority will evaluate whether there are enough grounds to continue the investigation.
The lead competent authority determines whether there is evidence of forced labour.
Once forced labour is confirmed, the competent authority will take enforcement action within its respective Member State. The customs authority will intercept the affected products at the border. These products may be reintroduced into the EU market only after producers have eliminated forced labour from their operations or supply chains.
How can you ensure you are well-prepared for the FLR?
To ensure you are well-prepared for the FLR, it is essential to undertake due diligence by following the:
Following these is the most effective way to identify, reduce and address the risk of forced labour in your value chain.
- The European Commission will publish the guidelines on 14 June 2026 to assist economic operators. These guidelines will outline what due diligence about forced labour entails. Also, it will explain how to identify the risk indicators for forced labour and effective methods for ending forced labour.
- The European Commission is developing a public database that will provide information on forced labour risks for specific products and geographic areas. This resource will help you prioritise principal aspects of your due diligence efforts.
- The report titled Assessing Forced Labour Risks in Dutch Imports may offer you valuable insights.
- Contact the advisors at the Netherlands Enterprise Agency via the RBC helpdesk for advice tailored to your business. business.
- Join the sectoral partnership programme, which supports businesses in implementing due diligence.
When will the FLR enter into force?
- The FLR came into effect on 13 December 2024.
- From 14 December 2027, it will apply to all businesses.
- On 14 June 2026, the European Commission will publish specific guidelines and a database that will provide information on forced labour risks for specific products and geographic areas. Once this information becomes available, we will publish details on this page.
Would you like more information?
You can find more details about the FLR online. Please refer to the links below for further information.
The advisors at the RBC Helpdesk will help you with tailored advice for your company. We will also answer your questions, for example, about CSRD and CSDDD.
- Ministry of Foreign Affairs