The EU has held political talks on a law that will ban the sale on the EU market of products made with forced labour, as well as the export of such products from the EU.

On 22 January 2024, the EU Council and Parliament held negotiations to agree the final text of the regulation, the proposal for which was published by the EU Commission in September 2022. The Committee on International Trade and the Committee on Internal Market and Consumer Protection of the EU Parliament previously proposed its position on the regulation in October 2022 (here and here).

The restrictions will cover all types of goods, whether manufactured in or imported into the EU, which are wholly or partially made using forced (including child) labour. The scope of the proposed regulation is expected to only extend to the use of forced labour during products’ production, manufacture, harvest and extraction, and will not include service activities such as transport or distribution.

This ban will be largely structured through customs rules and screening, with customs authorities empowered to suspend the release for free circulation or export of products they identify as being in violation of the ban. Under the Parliament’s current proposal, companies established in high risk-areas or producing high-risk goods will need to demonstrate that they do not used forced labour to comply and any workers who are involved in forced labour will be due compensation, although the details of who will pay this and the legal mechanisms for remediation are to be decided. The Commission’s enforcement powers and authority to initiate investigations are also uncertain.

The Council has set a deadline for early February for consensus to be reached on the final text in order for the regulation to be adopted before summer.


Jessica's practice focuses on international trade, encompassing: sanctions and export controls; customs; anti-bribery and corruption; and tax evasion. She joined Baker McKenzie from another global law firm in 2015. She studied and worked in both London and Paris, and has knowledge of both the English common law and French civil law systems. Jessica is the lead associate covering Brexit-related developments, analysing how they will affect the UK's trading position generally and clients' businesses specifically. She has helped clients to conduct assessments of how Brexit will impact their businesses and assisted in developing tailored Brexit.


Olof Johannesson is a member of Baker McKenzie’s International Commercial & Trade Group in Stockholm.


Johanna is an Associate in Baker McKenzie's London office.