The Regulation on Products Made with Forced Labour (Regulation (EU) 2024/3015, abbreviated as FLR) marks the EU’s first directly applicable regulation banning forced-labour-derived products across all sectors. It entered into force on 13 December 2024 and will be fully enforced as of 14 December 2027, with 2026 serving as a pivotal transition year. A high-risk goods inventory is due for release in June 2026, while EU Member States will finalise penalty provisions by December the same year. Covering entire supply chains, all product categories and all economic operators, the FLR is widely regarded as one of the world’s strictest bans against forced labour.
Full official title: Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labour on the Union market
Entry into Force & Implementation
- Entered into force on 13 December 2024; full application commences on 14 December 2027.
- Certain provisions (e.g. designation of competent authorities and database development) have taken effect in advance.
Legal Nature
Issued as an EU Regulation, it applies directly across all EU Member States without requiring transposition into national legislation, ensuring consistent enforcement throughout the bloc.
Legislative Objective
To eradicate forced labour present in products and supply chains entering the EU market, and bar any goods produced with forced labour – irrespective of origin, industry or operator size – from being imported into, exported out of or placed on the EU market.
1. Definition of Forced Labour aligned with ILO standards covering 11 high-risk categories
- General forced labour: Defined under ILO Convention No.29: all work or service exacted from any person under the menace of penalty and for which the said person has not offered himself voluntarily, including forced child labour involving minors under 18.
- State-imposed forced labour: Defined under ILO Convention No.105: labour compulsorily imposed by state authorities, including work enforced via political oppression or discriminatory measures.
End-to-end supply chain oversight: Full traceability across the entire supply chain from raw material extraction, cultivation and processing through to finished goods manufacturing. Products are banned once forced labour is identified at any production stage or in any component part.
Practices such as excessive overtime, retention of identity documents, mandatory security deposits, restrictions on resignation and physical punishment threats alongside child labour may all be deemed indicators of forced labour.
2. Core absolute prohibitions covering three categories of activities
- Placing or making available forced-labour-tainted products on the EU market (including cross-border online distance sales);
- Exporting such products from the EU territory;
- Deploying forced labour at any tier of the supply chain (including second- and third-tier suppliers), with no de minimis exemption.
3. Scope of application: universal coverage for all products and operators
- Product coverage: All industrial sectors and product categories across every supply chain stage from raw material sourcing to end-product sales; no exempted goods categories.
- Subject coverage: All economic operators, including EU and non-EU enterprises of all sizes (micro, small, medium and large), exporters, importers, distributors and e-commerce vendors, with no minimum threshold on turnover or headcount.
- Territorial coverage: Goods manufactured worldwide fall under the regulation once destined for EU market access or export from the EU.
4. Investigative procedures and punitive sanctions (stringent compliance consequences)
(1) Investigation procedures (full rollout post-2026)
- Preliminary inquiry: Competent authorities issue information requests, with a mandatory 30-calendar-day response deadline for targeted businesses.
- Formal investigation: Triggered upon identification of substantial forced labour risks; final rulings to be issued within nine months.
- Enforcement jurisdiction: National competent authorities oversee risks arising within EU territory, while the European Commission leads probes into non-EU supply chain risks.
(2) Penalty framework (Member States to finalise detailed implementing rules by end-2026)
- Market exclusion: Immediate ban on the placement of non-compliant goods on the EU market plus mandatory recall of already-circulated stock;
- Product disposal: Confiscated non-compliant goods must be destroyed or neutralised with no option for resale;
- Administrative fines: Penalties capped at up to 5% of the undertaking’s worldwide annual turnover (benchmarked against the EU CSDD Directive);
- Public listing: Named placement on a public forced labour violation register with permanent disclosure, severely damaging the company’s global commercial partnerships.
Gonex delivers compliant and efficient human resource solutions for Chinese enterprises expanding into EU jurisdictions. We enable firms to conduct cross-border workforce management in full legal compliance, allowing lawful hiring regardless of whether clients have established local legal entities overseas. Our end-to-end employee outsourcing covers the full lifecycle of overseas staff: onboarding & offboarding, payroll disbursement, statutory social contributions & personal income tax, employee benefits, work visas and employment permits under one roof.
Backed by in-depth expertise in local labour legislation and employment compliance risks, Gonex’s dedicated HR team mitigates potential legal liabilities, supporting Chinese businesses to set up operations smoothly and focus on core overseas expansion.
We guarantee full adherence to local labour regulations throughout the employment lifecycle to prevent penalties and financial losses stemming from non-compliance. Companies venturing abroad may fill in the form below to connect with our dedicated expansion consultants for full-spectrum compliant HR support.
Why Gonex?
Experienced Management Team: each member in the team has 10+ years experiences in Overseas Human Resources Management, composed of seasoned HR professionals.
Powerful connection: Gonex has established over 10 entities worldwide, along with more than 30 stable partners, together offering the most comprehensive overseas human resource services to our clients.
Strict compliance with laws and regulations: At every step in our service process, Gonex strictly adheres to local laws and regulations, ensuring our clients completely avoid any legal disputes.
Competitive price: Gonex’s services are 20% more affordable compared to other companies in the industry, allowing our clients to allocate more resources to their core business.
What Gonex offer?
Employment of Record: This service helps clients legally hire employees in countries or regions where they do not have a legal entity established.
Payroll BPO service: This includes payroll project implementation plan development, project deployment, payroll calculation, payment of funds, administration of statutory and supplementary benefits, customized reporting, and other comprehensive payroll services.
Global Mobility: Based on the company’s internationalization strategy, the company assigns employees to overseas branches/subsidiaries and handles visa and tax matters in accordance with local policies, while assisting in the compliance management of employees throughout their international assignment life cycle.
GONEX One-Stop Solution: Your strategic partner
Compliance and Legal Adherence: GONEX’s Employer of Record (EOR) service ensures legal compliance in employing local staff.
Cross-Border Payroll and Tax Management: Streamlined payroll services simplify cross-border management.
Flexible Employment Solutions: Adaptable employment services cater to changing business needs.
International Talent Dispatch: Support services facilitate the dispatch of key talent to overseas.
Digital HR Management Platform: Technology-driven solutions enhance management efficiency and cultural integration.
Who do we serve?
Gonex served 70+ clients to expand overseas. The incomes of our clients like Mengniu, Kuaishou and CHINT are up to 192.4 billion.
Let Gonex assist you and your company with handling such complex overseas hiring processes! To access more information on corporate international expansion cases, global employment guidelines, worldwide compensation management, regulations for various regional countries, and factory establishment manuals in different nations, you are welcome to visit the GONEX official website at www.letsgonex.com to download these resources or view our company’s business introduction in PDF format (https://letsgonex.com/in.pdf).
