ERWAY

State-imposed forced labour under the EUFLR

Forced labour imposed by state authorities is defined separately in Article 2, prioritised by the Guidelines in the risk-based approach, and handled differently at the remediation end — because a supplier cannot remediate what a state imposes.

Most of the Regulation's logic assumes a supplier who can change: the Guidelines' ladder runs from prevention through mitigation and remediation to responsible disengagement as a last resort. State-imposed forced labour breaks that assumption. Where the evidence shows a scheme operated by public authorities and minimal commitment to reform, the Guidelines say responsible disengagement may be the only viable route, and the risk-based assessment puts such cases first. The platform therefore keeps a separate flag for state-imposed risk, sourced from the database once it exists and from external reporting until then, and a remediation plan that opens on that flag defaults to the disengagement track rather than the ladder. The evidence file records the basis for that choice, because an authority reviewing a decision will ask why the company left rather than remediated — and the Guidelines' own text is the answer.

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