Guidelines on the Application of the Forced Labour Regulation
Implementation guidelines (C(2026) 4386) issued by the Commission under Article 11 of Regulation (EU) 2024/3015, explaining how the ban on products made with forced labour is applied and enforced. They cover: scope (all products and all economic operators, including online sales targeting EU consumers); the definition of forced labour (based on ILO Convention No 29) and risk indicators; competent authorities' risk-based prioritisation of investigations; preliminary and formal investigation procedures; prohibition decisions and withdrawal and disposal; customs enforcement and the penalties framework; and due diligence recommendations for economic operators (the OECD six-step approach). The guidelines are not legally binding; only the provisions of the parent Regulation are binding.
Timeline
- 26 Jun 2026AuthoritiesCommission adopts guidelines C(2026) 4386 (legal deadline under Article 11 of the parent Regulation: 2026-06-14)
- 30 Jun 2026Published with the Forced Labour Single Portal
- 3 Sep 2026Published in the Official Journal as C/2026/4637, content identical to the June version
- 14 Dec 2027Parent Regulation fully applicable
Key facts
- Reference
- Commission Notice C/2026/4637
- Adopted
- 26 Jun 2026
- Published
- 3 Sep 2026
- Status
- In force
- Amendments
- Issued under Article 11 of Reg (EU) 2024/3015 (FLR); not legally binding.
- Topic
- Labour & Human Rights
- Industries
- Cross-sector, Electronics Manufacturing
Main compliance requirements
Paid members only
The main compliance requirements, applicability questions and penalties are available in the ZC Smart Compliance Hub. Paid members and clients can sign in to the Hub to view them.
Related legislation
- Issued under Article 11 of Regulation (EU) 2024/3015 (ban on products made with forced labour). Refers to ILO Convention No 29 (Forced Labour) and the OECD Due Diligence Guidance. Related to Directive (EU) 2024/1760 (CSDDD), Regulation (EU) 2019/1020 (market surveillance) and Regulation (EU) No 952/2013 (Union Customs Code).
Official sources
Commission Notice – Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market