On 23 April 2024, the European Parliament approved the proposal of the EU Forced Labour Regulation (“Regulation“). The text of the Regulation was approved on first reading with 555 votes in favour, 6 against, and 45 abstentions. The officially adopted text can be found here.

Under the Regulation, all products (including their components) manufactured using forced labour or placed and made available on the market in the EU, or exported from the EU will be banned. The prohibition applies to products regardless of the sector, origin, or whether they are made domestically or imported, and also applies to each stage of a product’s supply chain, including its manufacture, harvest and extraction, and any working or processing related to the products.

The prohibition will be enforced by risk-based investigations led by the European Commission and EU Member States.

Next steps:

  • The next step in the legislative process is the final (and more formal) approval of the text from the EU Council. It is expected that this approval will be given after the European elections in June.
  • After approval, the Regulation will be published in the EU Official Journal and enter into force the day after publication.
  • EU Member States will have up to 36 months to begin applying the Regulation from its entry into force, meaning that companies should be prepared to begin complying with the Regulation’s requirements from mid-2027.
  • In the meantime, companies should begin to implement robust and effective compliance processes to address forced labour risks in their operations and value chains.

Please find our previous blog posts on the scope of the Regulation, including the investigatory authority of the European Commission and Member State national competent authorities here and here.

For information on the key similarities and differences between the existing US forced labour regime and proposed EU approach, the timeline and next steps for the EU’s new legislation, and how companies can best prepare and ensure compliance across their supply chains, please see our Forced Labour Webinar, hosted by Jessica Mutton, Chandri Navarro and Esmee Kooke available here.


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.


Esmee Kooke is a Junior Associate within the Amsterdam Indirect Tax team.