Supplier due diligence under the EU forced labour ban

The Regulation requires no due diligence. The Guidelines then say what an authority will make of the due diligence you did — and, specifically, that contractual clauses and supplier assurances are not sufficient on their own without follow-up and verification.

That sentence changes what a supplier questionnaire is for. A form that asks a supplier to confirm it uses no forced labour produces an assurance, which the Guidelines have already discounted. A request that asks for the recruitment-fee ledger, the payroll run and the document-retention policy produces evidence that can be graded. The platform generates the request from what the screening left open, ties each question to the ILO indicator it tests, names the evidence that settles it, and skips anything the EUDR legality file or the PPWR supplier data already answers — so a supplier is asked once. What comes back is graded verified, supported, asserted or not credible, following the Guidelines' further warning that social audits conducted where workers cannot speak freely are not credible evidence. The grade travels with the item into the evidence file, where an authority will see it.