EUFLR vs EUDR: forced labour ban and deforestation due diligence

EUDR tells an operator what to do and what to file. The Forced Labour Regulation tells no one to do anything and judges the product. They are built differently and they rest on the same supplier data.

Under EUDR an operator carries out due diligence — information, risk assessment, risk mitigation — and files a Due Diligence Statement in TRACES before placing the goods; seven commodities, a 2020 cut-off, geolocated plots. Under the Forced Labour Regulation there is no statement and no filing; any product, any sector; and the operator hears nothing until an authority opens a preliminary phase and asks for information. Where they meet is the evidence. EUDR's legality test covers labour rights and human rights protected under international law, so a completed EUDR legality file already answers part of what a forced-labour request will ask; the facility geolocations EUDR required are the facility geolocations the Guidelines list; the supplier questionnaires are the same suppliers. The platform reads the EUDR plot register and supplier records as the first tiers of the forced-labour map, marks each inherited row with its source, and asks the supplier only for what EUDR did not cover.