The EU forced labour regulations 2024/3015 have an implementation date on December 2027. As well as prohibiting “'all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.' within EU member states, they also put a due diligence requirement on companies to check that such practices do not occur in their supply chain. The way that Ireland have implemented the enforcement of these regulations (Irish Statutory Instrument 623 of December 2025) is typical. The Irish law applies to businesses of all sizes, in all sectors, and includes requirements to
- Update compliance and training programmes: Governance and training programmes should be updated to educate procurement teams, in-house counsel, risk managers, and senior leadership on their obligations.
- Supply-chain mapping: Conduct supply-chain mapping to identify any products or parts that may fall under the forced-labour import ban.
- Due-diligence: Incorporate due-diligence measures into procurement, contracting and supplier oversight.
A practical example within the food industry would by the business-to-business supply of canned tomatoes. At the moment, most companies’ supply chain mapping and VACCP assessments would take these back to their country of origin (e.g. “China”, which accounts for many of the tomatoes on the EU/UK b-2-b market). However, these new regulations imply a due-diligence requirement to go further down the chain, to give assurance that the production is not linked to previous reports of Uyghur forced labour in the Xinjiang region.
Photo by Marwan Ahmed on Unsplash, (with no implication that this image shows forced labour)
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