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ARTICLE · 29 JULY 2026

EU Forced Labor Guidelines: Mandatory Due Diligence In Disguise?

Jones Day
Jones Day
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The European Commission has issued detailed guidelines on the EU Forced Labor Regulation, which will prohibit products made with forced labor from entering or leaving the EU market starting December 2027. While technically non-binding, these guidelines establish a comprehensive six-step due diligence framework that companies should follow to ensure compliance across their entire supply chains, regardless of company size or sector. With enforcement approaching and significant penalties for non-compliance, bu

European UnionGovernment, Public Sector
Françoise Labrousse
Françoise Labrousse
Howard Sidman
Howard Sidman
Jürgen Beninca
Jürgen Beninca
Bethany K. Biesenthal
Bethany K. Biesenthal
Seth E. Engel
Seth E. Engel
Armelle Sandrin-Deforge
Armelle Sandrin-Deforge
Author LinkedIn connections

In Short

The Situation: On June 26, 2026, the European Commission published its long-awaited guidelines (the "Guidelines") on the application of the EU Forced Labor Regulation (EU) 2024/3015 (the "FLR"), which prohibits products made with forced labor from being "placed" on, made available on, or exported from the European Union ("EU"). The FLR, which enters into application on December 14, 2027, applies to all products—regardless of origin, sector, or type—and to all economic operators active in the EU, with no turnover or employee thresholds, even if they do not have a corporate presence in the EU.

The Result: While the Guidelines are legally nonbinding and state that the FLR does not technically impose any new due diligence obligations, they contain a detailed six-step due diligence framework that, in substance, amounts to a roadmap companies may be expected to follow.

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