EU forced labour regulation: what apparel importers need ready

What is the EU forced labour regulation?

Regulation (EU) 2024/3015 was published in the Official Journal on 12 December 2024 and entered into force the next day. It prohibits economic operators from placing products made with forced labour on the Union market or making them available on it, and from exporting such products. The ban covers every product type and every stage of the supply chain, including harvesting, extraction, production, manufacture and processing. It applies to domestic and imported goods alike.

Forced labour is defined by reference to the ILO Forced Labour Convention, 1930 (No. 29): work or service exacted under the menace of a penalty and for which the person has not offered themselves voluntarily. State-imposed forced labour is included.

The text is on EUR-Lex. The Commission published implementing guidelines for economic operators and authorities in June 2026; they are non-binding but indicate how the rules will be applied.

When does it apply to my shipments?

The prohibition applies from 14 December 2027. From that date it covers all products placed or made available on the EU market, including goods that were produced or imported earlier but not yet sold. Planning has to start well before that date because sourcing programmes, mill relationships and fibre contracts are set 12–18 months ahead. A garment ordered in autumn 2027 for sale in spring 2028 is already in scope.

How will enforcement work?

The regulation does not require every importer to certify its supply chain in advance. Instead it is enforced through risk-based investigations.

• Who investigates. National competent authorities in each Member State investigate products on their market. The European Commission leads investigations where the suspected forced labour is outside the EU.
• What triggers an investigation. Authorities assess substantiated concerns, using information from NGOs, workers, trade unions and companies, plus a Commission database of forced-labour risk areas and products.
• What authorities can ask for. They can request information on the supply chain and the operator’s due-diligence measures. Not providing it can be taken into account in the decision.
• What happens if forced labour is found. The authority can prohibit the product, require withdrawal from the market and disposal, and customs can suspend release of goods at the border. Member States set the penalties.
• Proportionality. Authorities are told to consider the size and resources of the company, so small and medium importers are treated differently from large groups.

In effect, the regulation puts a premium on being able to answer a question quickly: where was this garment’s cotton grown, who spun it, who knitted and dyed the fabric, and who sewed the garment?

Why does it matter for garments made in Bangladesh?

Bangladeshi factories are not the main concern. The exposure sits upstream. Garment makers in Bangladesh import cotton, yarn and fabric, and some inputs can trace back to regions that international bodies and governments have flagged for forced labour. Woven and denim programmes, which rely more on imported fabric, have more hops to document than knit programmes supplied by local mills, though knitwear also uses imported cotton.

Expect your buyers, retail customers and customs authorities to ask for the same records. The US Uyghur Forced Labor Prevention Act already works on a similar principle and has led to detentions of apparel shipments since June 2022, so evidence you assemble for one market helps in the other.

What should apparel importers prepare now?

1. Map each style to fibre level. Record the cotton or fibre origin, spinner, fabric mill, dye house, garment factory and any subcontractors, with names and addresses.
2. Put it in contracts. Require suppliers to disclose subcontracting, to pass on the obligation to their suppliers and to give audit access.
3. Collect evidence you can show. Purchase orders and commercial invoices across tiers, transaction certificates for certified fibre, mill and gin records, and third-party audit reports with dates.
4. Check your risk exposure. Compare your fibre and fabric origins against the Commission’s risk information and public lists of risk regions when they are published.
5. Design a response process. Decide who will answer an authority’s request, how fast, and how you will handle a supplier that cannot document an input.
6. Keep records long enough. Hold documents for at least as long as the regulation and your legal advisers say applies; do not delete supplier files after payment.

A buying house can collect factory-level documentation and request fabric-origin records from each tier as part of a programme. See the compliance guide for the wider set of audits and certificates, and the compliance checklist for documents by market.