Regulation (EU) 2024/3015 — the ban applies from 14 December 2027
The EU forced labour ban gives you 30 working days to show your supply chain. Have the file before the letter.
From 14 December 2027 no product made with forced labour may be placed on the EU market, made available on it or exported from it — any product, any sector, any company size, any tier of the chain. The Regulation asks you to do nothing until an authority writes; then it gives you 30 working days to answer, and what you can show in that window decides whether an investigation opens. This platform builds that answer now, product line by product line, from the supplier data you already hold.
In the preliminary phase the lead authority asks you for information and gives you 30 working days to reply. It then has 30 working days to decide whether there is a substantiated concern — and the Guidelines say the due diligence you can show at that point, and any traceability you cannot, both count.
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Dashboard
Noordwerk B.V. · 14 product lines · source review 14 Sep 2026
Product lines by exposure state
Decision match
0
No published decision or customs hold matches the map. Real decisions begin 14 Dec 2027.
Indicator flagged
2
Open flags with no answer yet. The work is yours.
Map incomplete
3
A share or a tier is unknown. The Guidelines treat this as a finding.
Awaiting supplier evidence
4
Requests out; the clock is the supplier's.
Remediation open
1
A confirmed finding with a plan on the Guidelines' ladder.
Evidence-ready
4
Mapped, screened, file complete. Could answer a request today.
Components mapped
88 %
Share of the bill of materials with a known origin, across all lines.
Screenings this month
31
Database, indicator and signal checks, each with its source and date.
Procedural clocks
Windows the Regulation opens on an event. Three have no event yet and say so.
Reply to request · Art. 17(3)
19 of 30 working days
Running — opened on the event named
Authority decision · Art. 17(4)
Not started
Not started — no event has opened this window
Investigation · Art. 20(1)
Not started
Not started — no event has opened this window
Compliance period · Art. 20(5)
Not started
Not started — no event has opened this window
Needs attention
Ordered by state precedence, then by the component share involved.
| State | Product line | Finding | Owner | Due | Next action |
|---|---|---|---|---|---|
Indicator flagged | WW-2210 Cotton-blend workwear | Recruitment-fee indicator at tier-3 spinner (14 % share) | Sourcing | Immediate | Request payroll and fee ledger |
Indicator flagged | GL-0380 Nitrile gloves | Region match in external reporting, tier 2 | Sourcing | Immediate | Confirm facility geolocation |
Awaiting supplier evidence | WW-2210 Cotton-blend workwear | Request out to Ravi Spinning Mills | Supplier | 26 Sep 2026 | Reminder scheduled |
Map incomplete | HV-1150 Hi-vis vests | Reflective tape origin unknown (9 % share) | Procurement | 3 Oct 2026 | Obtain tier-2 declaration |
Remediation open | BT-0470 Safety boots | Excessive overtime confirmed at tier-1 assembler | Compliance | 30 Nov 2026 | Re-check scheduled |
Decision watch
Published decisions and customs holds matched against this company's map. Worked examples until 14 Dec 2027.
| Reference | Scope | Published | Match against map | State |
|---|---|---|---|---|
| EXAMPLE-2027-001 | Polysilicon ingots, named facility, third country | example | No facility, region or product in map | Screened, file incomplete |
| EXAMPLE-2027-002 | Cotton yarn, named region, third country | example | Region overlaps tier-3 spinner for WW-2210 | Indicator flagged |
Every product, every sector, every tier
- Textiles and apparel
- Solar and photovoltaics
- Electronics and semiconductors
- Agri-food
- Automotive
- Fisheries
- Metals and minerals
- Consumer goods
What the Regulation already fixes
The prohibition
Article 3
Placing, making available, exporting
Who leads the case
Articles 14–15
Commission outside the EU, Member State inside
The preliminary clock
Article 17
30 working days to reply, 30 to decide
The decision clock
Article 20
9 months; at least 30 working days to comply
The replaceable part
Article 20
A decision can be limited to the part
Review
Article 21
Withdrawn once forced labour is eliminated
General application
Article 26
Published decisions bind every operator
Customs
Articles 23–31
Release suspended or refused at the border
The Regulation is adopted, in force and unamended. Only its date of application lies ahead.
30
Working days to answer a request for information in the preliminary phase. What is not in the file by then is, for the authority's purposes, not there.
9
Months from the opening of an investigation to a decision — prohibition, withdrawal, disposal — that is published and binds every operator placing the product.
0
New due diligence, audit or reporting obligations created by the Regulation. It is an obligation of result; what you did to reach it is what the authority reads.
Figures and article references reflect a source review dated 14 September 2026. Every legal statement on this page carries its article, its source and that retrieval date; statements drawn from the Commission Guidelines say so.
Modules
A screen for each thing the authority will ask about
The Commission Guidelines list what a request for information may cover: supplier maps, purchase records, chain-of-custody, facility locations, policies, remediation. Each module below is one item on that list, held per product line, and each is a real screen in the product.
Product lines by exposure state, and the four clocks
No score. A line is in one of seven named states, and the dashboard counts them. Underneath, the Regulation's four procedural clocks — three of which have not started, and say so, because a countdown to a letter nobody has sent is a guess dressed as a deadline.
- Counts by exposure state, never averaged into one figure
- Decision matches shown apart from your own findings
- Clocks that read 'not started' until an authority starts them
Dashboard
Noordwerk B.V. · 14 product lines · source review 14 Sep 2026
Product lines by exposure state
Decision match
0
No published decision or customs hold matches the map. Real decisions begin 14 Dec 2027.
Indicator flagged
2
Open flags with no answer yet. The work is yours.
Map incomplete
3
A share or a tier is unknown. The Guidelines treat this as a finding.
Awaiting supplier evidence
4
Requests out; the clock is the supplier's.
Remediation open
1
A confirmed finding with a plan on the Guidelines' ladder.
Evidence-ready
4
Mapped, screened, file complete. Could answer a request today.
Components mapped
88 %
Share of the bill of materials with a known origin, across all lines.
Screenings this month
31
Database, indicator and signal checks, each with its source and date.
Procedural clocks
Windows the Regulation opens on an event. Three have no event yet and say so.
Reply to request · Art. 17(3)
19 of 30 working days
Running — opened on the event named
Authority decision · Art. 17(4)
Not started
Not started — no event has opened this window
Investigation · Art. 20(1)
Not started
Not started — no event has opened this window
Compliance period · Art. 20(5)
Not started
Not started — no event has opened this window
Needs attention
Ordered by state precedence, then by the component share involved.
| State | Product line | Finding | Owner | Due | Next action |
|---|---|---|---|---|---|
Indicator flagged | WW-2210 Cotton-blend workwear | Recruitment-fee indicator at tier-3 spinner (14 % share) | Sourcing | Immediate | Request payroll and fee ledger |
Indicator flagged | GL-0380 Nitrile gloves | Region match in external reporting, tier 2 | Sourcing | Immediate | Confirm facility geolocation |
Awaiting supplier evidence | WW-2210 Cotton-blend workwear | Request out to Ravi Spinning Mills | Supplier | 26 Sep 2026 | Reminder scheduled |
Map incomplete | HV-1150 Hi-vis vests | Reflective tape origin unknown (9 % share) | Procurement | 3 Oct 2026 | Obtain tier-2 declaration |
Remediation open | BT-0470 Safety boots | Excessive overtime confirmed at tier-1 assembler | Compliance | 30 Nov 2026 | Re-check scheduled |
Decision watch
Published decisions and customs holds matched against this company's map. Worked examples until 14 Dec 2027.
| Reference | Scope | Published | Match against map | State |
|---|---|---|---|---|
| EXAMPLE-2027-001 | Polysilicon ingots, named facility, third country | example | No facility, region or product in map | Screened, file incomplete |
| EXAMPLE-2027-002 | Cotton yarn, named region, third country | example | Region overlaps tier-3 spinner for WW-2210 | Indicator flagged |
Every component, with its share of the product
A decision names a product, and can be limited to a replaceable part. The share of a suspect part in the final product is also one of the three criteria an authority uses to decide what to look at first. So the bill of materials carries a percentage against every component, and every component carries its own tier path.
- Share per component, imported from the ERP or the PPWR bill of materials
- A flag on a tier-3 input shows on the component it feeds, not on the whole line
- Lines with unknown shares are marked 'map incomplete', which the Guidelines treat as a finding
WW-2210 · Cotton-blend workwear range
7 components · 92 % origin known · sold in NL, DE, BE, FR
Components, shares and tier paths
Share by weight of the finished garment. A flag shows on the component it concerns, not on the line.
| Component | Share | Tier path | Origin facility | State |
|---|---|---|---|---|
Woven shell fabric 65 % polyester / 35 % cotton twill | 61 % |
| Denizli, TR · geolocated | Screened, file incomplete |
Spun cotton yarn Ring-spun Ne 30 | 14 % |
| Ludhiana, IN · not geolocated | Indicator flagged |
Sewing thread Core-spun polyester | 2 % |
| Bursa, TR · geolocated | Evidence-ready |
Zips and fasteners Nylon coil, brass slider | 5 % |
| Çerkezköy, TR · geolocated | Evidence-ready |
Reflective tape Glass-bead microprism | 3 % |
| — | Map incomplete |
Knee-pad pockets Cordura nylon | 9 % |
| Bursa, TR · geolocated | Evidence-ready |
Labels and packaging Woven label, poly bag | 6 % |
| Istanbul, TR · from PPWR | Evidence-ready |
- Placed on the market by
- Noordwerk B.V. (importer)
- Manufacturer
- Ekin Tekstil A.Ş., Denizli (tier 1)
- Units on EU market, 12 months
- 184,000
- Lead authority if investigated
- European Commission (suspected forced labour outside the EU)
Why the 14 % matters
If the flag on the spun yarn were confirmed, Article 20(4) would let a decision be limited to that part if it can be replaced — and the share is one of the criteria an authority weighs when deciding what to investigate first. A line without shares cannot make either argument.
Where only a part of the product is found to be made with forced labour and that part can be replaced, the order shall apply to that part only.
EUR-Lex, CELEX 32024R3015 · retrieved 14 Sep 2026Open source
Tier-n, facility by facility, from the register you already have
The map is a table of facilities — name, address, geolocation, tier, what it feeds — because that is what an authority asks for. Suppliers already in your EUDR plot register or PPWR supplier data arrive with their evidence attached; the map shows where the known chain stops.
- Inherits EUDR and PPWR supplier records, with their sources
- Geolocation per facility, the same field EUDR already made you collect
- Gaps listed as gaps, with the tier and the component they leave open
Supply-chain map
WW-2210 · 9 facilities across 3 tiers · 8 geolocated
6 of 9 rows came from the EUDR and PPWR registers
Facilities geolocated for EUDR and suppliers recorded for PPWR arrive with their evidence and sources attached. They are marked by origin so a reader can tell an inherited row from a new claim.
| Tier | Supplier | Facility | Geolocation | Source | State |
|---|---|---|---|---|---|
| T1 | Ekin Tekstil A.Ş. Assembly, all components | Denizli OSB, Plant 2 Türkiye | 37.7912, 29.1748 | PPWR supplier register | Evidence-ready |
| T2 | Denizli Dokuma Woven shell, spun yarn | Weaving mill, Çardak Türkiye | 37.8237, 29.6691 | EUDR plot register | Screened, file incomplete |
| T2 | Coats Türkiye Sewing thread | Bursa plant Türkiye | 40.2261, 29.0621 | PPWR supplier register | Evidence-ready |
| T2 | YKK Türkiye Zips and fasteners | Çerkezköy plant Türkiye | 41.2854, 27.9973 | Supplier declaration, verified | Evidence-ready |
| T2 | Bursa Teknik Tekstil Knee-pad pockets | Nilüfer plant Türkiye | 40.2141, 28.9410 | PPWR supplier register | Evidence-ready |
| T2 | Unknown Reflective tape | — — | Not geolocated | No declaration received | Map incomplete |
| T3 | Aegean Polyester Polyester filament | Aliağa plant Türkiye | 38.7995, 26.9727 | Supplier declaration, supported | Screened, file incomplete |
| T3 | Ravi Spinning Mills Spun cotton yarn | Unit 2, Ludhiana India | Not geolocated | Named by Denizli Dokuma | Indicator flagged |
| T3 | Etiket Sanayi Labels and packaging | Ikitelli plant Türkiye | 41.0645, 28.7967 | PPWR supplier register | Evidence-ready |
Where the known chain stops
- Reflective tape (3 % share): no tier-2 supplier declared. Ekin Tekstil to name the source.
- Ravi Spinning Mills: facility named but not geolocated. Coordinates requested with the evidence pack.
- Cotton lint behind Ravi Spinning Mills (tier 4): not asked yet — opens once tier 3 is settled.
The map checked against the database, the indicators and the signals
Three kinds of source, kept apart because an authority treats them differently: the Commission's risk database of areas and products, the ILO's eleven indicators applied to what suppliers have answered, and external signals — sanctions, enforcement actions, credible reporting. Every hit carries its source and retrieval date.
- State-imposed forced labour flagged separately, as the Guidelines prioritise it
- The Commission database shown as 'in development' until it exists — nothing inferred
- Indicator counts per supplier, so a pattern is visible before a case is
Risk screening
WW-2210 · last run 14 Sep 2026 06:10 · 3 sources
Sources checked
Commission risk database
Art. 8 · areas and products
In development
Status checked 14 Sep 2026
ILO indicators on supplier answers
11 indicators · questionnaire responses
2 hits
Answers as at 12 Sep 2026
External signals
Sanctions, enforcement, reporting
1 hit
Feeds retrieved 14 Sep 2026
Hits on this line
| Signal | Scope | Indicator | Source | State |
|---|---|---|---|---|
| Recruitment fees charged to migrant workers | Ravi Spinning Mills, Ludhiana (tier 3) | Debt bondage | Supplier questionnaire, Q7 12 Sep 2026 | Indicator flagged |
| Identity documents held by employer | Ravi Spinning Mills, Ludhiana (tier 3) | Retention of identity documents | Supplier questionnaire, Q9 12 Sep 2026 | Indicator flagged |
| Regional reporting on spinning sector | Punjab, IN · spinning | Abuse of vulnerability | External reporting feed 3 Sep 2026 | Awaiting supplier evidence |
ILO indicators, hits across all suppliers
Counts of open hits per indicator across the 41 suppliers in the register. A pattern across suppliers is visible before any single case is.
- Abuse of vulnerability1
- Deception0
- Restriction of movement0
- Isolation0
- Physical and sexual violence0
- Intimidation and threats0
- Retention of identity documents1
- Withholding of wages0
- Debt bondage2
- Abusive working and living conditions0
- Excessive overtime1
The complete lack of, or inability to provide, traceability information may weigh negatively in the overall assessment.
OJ C/2026/4637, 3 Sep 2026 · retrieved 14 Sep 2026Open source
Ask for the evidence, not the assurance
Each question is tied to the indicator it tests and names the evidence that settles it — a payslip run, a recruitment-fee ledger, a worker-voice channel. A signed clause is accepted and filed, and graded as what the Guidelines say it is: not sufficient on its own. Questions your EUDR legality file already answers are shown as skipped.
- Questionnaire generated from the gaps, not from a template
- Evidence graded: verified, supported, asserted, not credible
- Suppliers already asked under EUDR or PPWR are not asked again
Evidence request EVR-0417
Ravi Spinning Mills · tier 3 · WW-2210 spun cotton yarn (14 %)
Generated from 2 open indicators and 1 map gap
Five questions. Three more were skipped because the EUDR legality file and the PPWR supplier data already answer them; the supplier can see that on the form.
| Question | Indicator tested | Evidence that settles it |
|---|---|---|
| Are workers charged recruitment or placement fees, directly or through an agent?Spun yarn | Debt bondage | Recruitment-fee ledger and agent contracts for the last 12 months Verified |
| Who holds workers' passports and identity documents, and where?Spun yarn | Retention of identity documents | Document-retention policy plus a dated locker inventory Supported |
| Provide the payroll run for Unit 2 for August 2026.Spun yarn | Withholding of wages | Payroll extract with deductions itemised Verified |
| Is there a channel through which workers can raise a grievance without the line manager?Spun yarn | Isolation | Channel description and the last quarter's case log, anonymised Supported |
| Provide the coordinates of Unit 2 and the name of the cotton lint supplier.Spun yarn | Traceability | Geolocation and the tier-4 supplier name Supported |
- Supplier
- Ravi Spinning Mills, Unit 2, Ludhiana
- Sent
- 12 Sep 2026 · reminder 19 Sep
- Due
- 26 Sep 2026
- Language
- English / Punjabi
- Received so far
- Signed assurance letter (graded: asserted)
Not asked — already answered
Questions whose answer sits in an earlier file. The source is shown so nobody re-asks.
Does the facility hold a valid factory licence?
Answered in the EUDR legality file, 2 Jun 2026 — legality test covers labour law.
Which spinning process and yarn counts does Unit 2 produce?
PPWR supplier data, material declaration MD-2291.
What is the facility's registered address?
PPWR supplier register, verified against the invoice.
The assurance letter received on 13 Sep 2026 has been filed and graded 'asserted'. The Guidelines say contractual clauses and supplier assurances are not sufficient on their own without follow-up and verification, so it does not close either indicator.
This request runs on the supplier's clock, not the Regulation's. If an authority's request arrives before 26 Sep, the file goes out with the assurance graded as it is and the gap stated as a gap.
The 30-working-day pack, assembled before the request
A checklist per product line that mirrors the Guidelines' own list of what may be requested, in their order. Each item is present, partial or missing, carries its grade and its source, and the file exports as one bundle. This is the screen someone opens when the letter arrives, so the clocks live here too.
- Guidelines request items as rows: policies, maps, purchase records, chain-of-custody, facilities
- Completeness shown per line; gaps listed by what closes them
- One export, dated, with every item's source and grade
Evidence file · WW-2210
Cotton-blend workwear range · organised in the Guidelines' request order
Reply to request · Art. 17(3)
19 of 30 working days
Running — opened on the event named
Authority decision · Art. 17(4)
Not started
Not started — no event has opened this window
Investigation · Art. 20(1)
Not started
Not started — no event has opened this window
Compliance period · Art. 20(5)
Not started
Not started — no event has opened this window
What a request for information may cover
Rows follow the Commission Guidelines' list. Each shows whether it is present, its grade and where it came from.
78%
| Item | Status | Grade | Source |
|---|---|---|---|
Forced-labour policy and code of conduct Guidelines set 11 · policies | Present | Verified | Noordwerk policy v3, board-approved 2 Feb 2026 |
Training records, sourcing team Guidelines set 11 · training | Present | Supported | LMS export, 14 staff, 2026 |
Sectoral risk assessment — textiles Guidelines set 4 · risk assessment | Present | Supported | Screening run 14 Sep 2026, sources attached |
Multi-tier supplier map with facilities Guidelines set 11 · supply chain maps | Partial | Supported | 9 facilities, 8 geolocated; tier-2 tape supplier unknown |
Purchase orders and invoices, 12 months Guidelines set 11 · purchase records | Partial | Verified | ERP export; tier-2 and tier-3 orders via Ekin Tekstil pending |
Packing lists and shipping documents Guidelines set 11 · shipping | Present | Verified | Customs declarations, 2025–2026 |
Chain-of-custody and certificates of origin Guidelines set 11 · traceability | Present | Verified | Form A certificates; cotton lint CoC pending tier 4 |
Facility geolocation Guidelines set 11 · facility data | Partial | Verified | 8 of 9 facilities; Ravi Spinning Mills requested |
Supplier questionnaires and evidence Guidelines set 11 · due diligence | Partial | Asserted | EVR-0417 open; assurance letter received |
Remediation plans and grievance records Guidelines set 11 · remediation | Missing | — | No confirmed finding on this line yet |
Digital Product Passport identifiers Guidelines set 11 · where applicable | Present | Supported | Not applicable to workwear at source review — recorded as such |
- Last export
- None — file has never been requested
- Items
- 11 · 6 present · 4 partial · 1 missing
- Lowest grade on a present item
- Asserted (supplier assurance)
- Would go out today as
- Complete with two stated gaps
What closes the file
- Payroll extract and recruitment-fee ledger from Ravi Spinning Mills (EVR-0417, due 26 Sep) — moves questionnaires from 'asserted' to 'verified'.
- Tier-2 supplier name for the reflective tape (via Ekin Tekstil, due 3 Oct) — completes the map row and the purchase-order bundle.
The economic operator shall respond to the request for information within 30 working days of receipt.
EUR-Lex, CELEX 32024R3015 · retrieved 14 Sep 2026Open source
Prevention first, disengagement last — and the way back
The Guidelines set an order: prevent and mitigate, remediate, and disengage responsibly only where a supplier shows no will to change; state-imposed forced labour is the exception where leaving may be the only route. Every plan names its rung. And because Article 21 lets a decision be withdrawn once the forced labour is eliminated, the review dossier is built from the plan as it runs.
- Plans on the Guidelines' ladder, with the rung named
- State-imposed cases handled on their own track
- Article 21 review dossier assembled while the plan runs, not afterwards
Remediation
2 plans running · 1 review dossier in progress
Plans on the Guidelines' ladder
| Finding | Measure | Rung | Next check | State |
|---|---|---|---|---|
Excessive overtime, tier-1 assembler Sunrise Footwear Co. · BT-0470 | Shift roster capped at legal maximum; overtime paid at premium; monthly roster extract | 2 · Mitigate | 30 Nov 2026 | Remediation open |
Recruitment fees, tier-3 spinner Ravi Spinning Mills · WW-2210 | Fees repaid to 61 workers; agent contract terminated; worker-voice channel opened | 3 · Remediate | 15 Oct 2026 | Remediation open |
The order the Guidelines set
Disengagement is the last rung, not the first — except where the forced labour is state-imposed and the evidence shows no will to change.
- 1
Prevent
Policies, contracts and purchasing practices that do not create the conditions — lead times and prices that do not force overtime or fee-based recruitment.
- 2
Mitigate
Stop the practice where found, with a dated measure and a re-check.
- 3
Remediate
Repay fees, return documents, pay withheld wages; provide or cooperate with a grievance mechanism, in proportion to the company's involvement.
- 4
Disengage responsibly
Only where a supplier shows no will to change, with notice and without harming the workers concerned. The default route for state-imposed forced labour.
Article 21 review dossier · Ravi Spinning Mills
If a decision were ever taken on this yarn, Article 21 lets it be withdrawn on new substantial evidence that the forced labour has been eliminated. The dossier is built from the plan as it runs rather than reconstructed afterwards.
- Fee repayment ledger, 61 workers, countersigned
- Agent contract termination and replacement recruitment policy
- Worker-voice channel: first quarter's anonymised log
- Independent re-check with unrestricted worker access
Other operators' decisions, read against your map
Decisions are published on the Single Portal and are of general application — a decision against another importer's product binds you if you place the same product. The watch reads every published decision and every customs hold against your facilities, regions and products, and a match is the worst state a line can be in.
- Published decisions matched on product, facility and region
- Customs holds surfaced with their reference and port
- Empty until 14 December 2027, and honest about it
Decision watch
Single Portal decisions and customs holds, matched against the map daily
Published decisions
| Reference | Authority | Scope | Published | Match against map | State |
|---|---|---|---|---|---|
| EXAMPLE-2027-001 | European Commission | Polysilicon ingots from a named facility, third country | example | No facility, region or product in map | Screened, file incomplete |
| EXAMPLE-2027-002 | European Commission | Cotton yarn from a named region, third country | example | Region overlaps Ravi Spinning Mills (tier 3, WW-2210, 14 %) | Indicator flagged |
| EXAMPLE-2027-003 | Member State authority | Agricultural produce, named operator inside the Union | example | No match | Screened, file incomplete |
These rows are worked examples and are labelled as such. The prohibition applies from 14 December 2027; no decision under Article 20 exists before that date, and the watch will show none.
A decision against someone else can bind you
Article 26 makes decisions of general application: every operator placing the named product on the market is bound, whether or not it was investigated. That is why the watch matches on product, facility and region rather than on the company named in the decision.
Customs holds
Suspensions of release notified through the market surveillance system's forced-labour module. Matched on the product identifiers in the decision.
- EXAMPLE-HOLD-01example
Rotterdam · HS 6203 workwear · suspension pending authority reply — worked example
Decisions shall be published on the Forced Labour Single Portal and shall be of general application.
EUR-Lex, CELEX 32024R3015 · retrieved 14 Sep 2026Open source
The articles, the eleven guideline sets, and what each is worth
Every regulatory statement in the product resolves to a row here: the article or Guidelines paragraph, the quoted words, the source, the retrieval date and the certainty class — in the Regulation, in the Guidelines, or an ERWAY decision. The two instruments that do not exist yet are marked as such.
- Certainty class on every row: A in the text, D in the Guidelines, E ours
- Risk database and submission point shown with their real status
- Retrieval date on every source, re-checked on a schedule
Regulatory library
Regulation (EU) 2024/3015 and Guidelines C/2026/4637 · source review 14 Sep 2026
| Reference | Provision | Certainty | Date | Status |
|---|---|---|---|---|
| Art. 3 | Prohibition of products made with forced labour EUR-Lex CELEX 32024R3015 | Certainty A | 14 Dec 2027 | Applies |
| Art. 2 | Definitions — forced labour (ILO C29), state-imposed, product made with forced labour, economic operator EUR-Lex CELEX 32024R3015 | Certainty A | 13 Dec 2024 | In force |
| Art. 8 | Database of forced-labour risk areas and products Single Market portal | Certainty A | In development | Not yet available |
| Art. 9 | Single information submission point Single Market portal | Certainty A | 14 Dec 2027 | Not yet available |
| Art. 11 | Commission Guidelines — published 30 Jun 2026, OJ 3 Sep 2026 OJ C/2026/4637 | Certainty A | 3 Sep 2026 | Done |
| Art. 17 | Preliminary phase — 30 working days to reply, 30 to decide EUR-Lex CELEX 32024R3015 | Certainty A | 14 Dec 2027 | Applies |
| Art. 20 | Decisions — 9 months, prohibition, withdrawal, disposal, replaceable part, ≥ 30 working days to comply EUR-Lex CELEX 32024R3015 | Certainty A | 14 Dec 2027 | Applies |
| Art. 21 | Review of decisions on new substantial evidence EUR-Lex CELEX 32024R3015 | Certainty A | 14 Dec 2027 | Applies |
| Art. 37 | Penalties — national rules notified by 14 Dec 2026 EUR-Lex CELEX 32024R3015 | Certainty A | 14 Dec 2026 | Applies |
| Guidelines 11 | Evidence an authority may request; assurances not sufficient alone; restricted audits not credible OJ C/2026/4637 | Certainty D | 3 Sep 2026 | Done |
| ERWAY | Seven exposure states and their precedence Product decision | Certainty E | 14 Sep 2026 | In force |
The eleven guideline sets
Non-binding, and cited on every screen that rests on them with certainty class D.
01Scope and definitions
What is a product, an operator, forced labour; state-imposed and child labour.
02Coordination
Lead authority allocation; the Union Network.
03Submissions of information
How the public and civil society report; the submission point.
04Risk assessment
Scale and severity, volume, share of the part; priority for state-imposed cases.
05Preliminary phase
The request, the 30 working days, what is weighed; traceability gaps weigh negatively.
06Investigations
Information requests, inspections, non-cooperation as evidence.
07Decisions
Content, time to comply, replaceable parts, strategic products.
08Review
New substantial evidence; withdrawal where forced labour is eliminated.
09Enforcement and customs
Suspension and refusal of release; disposal per the waste hierarchy.
10Penalties
Five-step calculation method for Member States.
11Guidance for economic operators
The OECD six steps; evidence list; what assurances and audits are worth.
Every source is re-checked on a schedule. A row whose source has changed since its retrieval date is flagged, not silently updated.
The regulation
A ban with an investigation attached — not a due diligence law
Regulation (EU) 2024/3015 does one thing: from 14 December 2027 it prohibits placing, making available and exporting products made with forced labour, at any stage of their chain, from any country. It imposes no reporting, no audit and no process duty. Instead it gives authorities a procedure for establishing that the prohibition has been breached, and it tells them what to weigh while they do it. What you did to know your chain is not an obligation. It is the evidence.
Source: Regulation (EU) 2024/3015, EUR-Lex (CELEX 32024R3015); Commission Guidelines C/2026/4637, OJ 3 September 2026. Retrieved 14 September 2026.
What the text fixes
Article 3
The prohibition
Economic operators shall not place or make available on the Union market, or export from it, products made with forced labour. Online and distance sales targeting EU customers are included. Services are not products and are out.
Article 2
Forced labour, as the ILO defines it
All work or service exacted from any person under the menace of any penalty and for which the person has not offered themselves voluntarily — ILO Convention No. 29. State-imposed forced labour and forced child labour are named separately, and the Guidelines put state-imposed cases first in line.
Article 2
'Made with forced labour'
Forced labour used in whole or in part at any stage of extraction, harvest, production or manufacture, including working or processing at any stage of the supply chain. A component is enough. There is no de minimis and no size threshold.
Articles 14–17
How a case is chosen
Authorities work from a risk-based assessment: the scale and severity of the suspected forced labour, the quantity of product on the Union market, and the share of the suspect part in the final product. State-imposed forced labour is a priority in its own right.
Article 17
What is weighed before an investigation
In the preliminary phase the authority considers the due diligence the operator has carried out, any remediation, and any other steps taken. The Guidelines add that the inability to provide traceability information may weigh negatively in the overall assessment.
Article 26
Decisions bind everyone
A decision is published on the Forced Labour Single Portal and is of general application: it binds every economic operator placing the product on the market, not only the one investigated. Customs act on it at the border.
The procedure, with its clocks
Five stages, four of them with a duration written into the text. None of the clocks runs until its event happens, which is why the product shows them as 'not started' rather than counting down to a letter that may never come.
- Preliminary phaseArticle 1730 working days to reply
- The lead authority asks the operator for information on what it has done to identify, prevent, mitigate or bring to an end forced labour in its chain. The operator has 30 working days. The authority then has 30 working days to decide whether there is a substantiated concern — a reasonable, verifiable indication that the product was likely made with forced labour.
- InvestigationArticles 18–19Further requests; inspections in exceptional cases
- The authority may request further documents and information from the operator and from others, and may carry out checks and inspections, including in third countries with the government's consent. The Guidelines say a refusal to cooperate may be treated as evidence together with other factors.
- DecisionArticle 209 months; ≥ 30 working days to comply
- Within nine months of opening the investigation the authority decides. A decision prohibits placing, making available and exporting, orders withdrawal — including from online interfaces — and orders disposal. Where the part made with forced labour can be replaced, the order can be limited to that part. The time to comply is not less than 30 working days.
- Publication and customsArticles 23–31On notification
- The decision is published on the Single Portal and communicated to customs through the forced-labour module of the market surveillance system. Customs suspend release of the product at the external border and refuse it once the decision applies.
- ReviewArticle 21On request, with new evidence
- The operator may ask for review, submitting new substantial information showing the product is no longer made with forced labour. Where the authority finds the forced labour has been eliminated, the decision is withdrawn. This is the only route back, and it runs on evidence.
Who the Regulation reaches
Everyone who places, makes available or exports a product. There is no exemption for small and medium-sized enterprises, no carve-out by sector, and no threshold on value or volume. The Guidelines promise proportionality in enforcement; the prohibition itself is the same for a marketplace seller and a carmaker.
EU importers and brand owners
First in line for a request: the product is on the Union market under your name, and the lead authority will be the Commission if the suspected forced labour is abroad.
Manufacturers outside the EU
Your goods are in scope the moment they are placed on the market by anyone. Your EU customer's evidence file is your facilities, your suppliers and your records — or its gaps.
Distributors and retailers
Making available is prohibited as much as placing. A published decision on a product you sell binds you from the day it applies, whoever imported it.
Online and distance sellers
Offering to EU consumers counts as making available. Withdrawal orders extend to online interfaces, and platforms may be ordered to remove listings.
Enforcement
Enforcement is product-level before it is fine-level. A decision takes the product off the market, out of the customs queue and, unless it is a strategic product or a replaceable part, into disposal in line with the waste hierarchy. Penalties are national: Article 37 requires Member States to lay down rules and notify them by 14 December 2026, and the Guidelines describe a five-step method for setting them — gravity, duration, mitigating and aggravating factors, thresholds, and the effectiveness-proportionality-dissuasiveness test. Amounts are not set in the Regulation and are not yet all notified. A penalty attaches to non-compliance with a decision; the ban itself is enforced by the decision.
Timeline
Two dates ahead, and four clocks that have not started
The calendar is short. The Regulation entered into force in December 2024, its Guidelines and portal arrived in mid-2026, and the ban applies from 14 December 2027 — one date, contingent on nothing. What the Regulation adds to that calendar is a set of durations that only begin when an authority acts. The product shows those as what they are: windows, not deadlines, until the day one opens.
- Done— Happened as at 14 September 2026
- Fixed date— A calendar date in the Regulation, contingent on nothing
- Procedural clock— A duration that starts on an event, not a date
The Regulation is complete and its support instruments are largely in place. The one still marked 'in development' at the source review is the risk database.
13 December 2024
Article 39
Entry into force, the day after publication in the Official Journal. The three-year run to application starts here.
14 December 2025
Article 5
Member States designate their competent authorities and notify the Commission. The list is published on the Single Market Compliance Space.
30 June 2026
Articles 11–12
The Commission publishes its Guidelines and opens the Forced Labour Single Portal, with the SME preparedness checklist and the sector webinar programme.
3 September 2026
Article 11
The Guidelines appear in the Official Journal as C/2026/4637 — eleven sets covering scope, submissions, risk assessment, the preliminary phase, investigations, decisions, review, customs, penalties and guidance for operators.
'How many of our product lines could not answer a request today' is a fair question and the platform answers it. 'How many days until our investigation ends' is not, because no investigation has opened.
Exposure states
Seven named states instead of one score
The Regulation defines no operator-side risk index. Its three risk criteria — scale and severity, volume on the market, share of the suspect part — are the authority's tools for choosing what to investigate, not a scale a company sits on. A synthesised score would invent that scale, and would let one decision match average away into a reassuring green. So each product line is in one of seven named states, each tied to the fact that produced it, and the platform counts them.
A published decision or a customs hold names a product, a facility or a region that is in this line's map. Decisions are of general application, so this binds you whoever was investigated.
A database match, an ILO indicator or an external signal is open and has not been answered. The work is yours: ask the supplier, obtain the evidence, or open a plan.
An indicator was confirmed and a plan is running on the Guidelines' ladder — prevent, mitigate, remediate, disengage. The Article 21 review dossier is being built from it.
A request is out and the clock is the supplier's, not yours. Reminders run; the line does not move until evidence arrives and is graded.
A component's share is unknown, or a tier beyond the first is. The Guidelines say an inability to provide traceability information weighs negatively — so this is a finding, not the absence of one.
Mapped and screened with nothing open, but the evidence file has gaps against the Guidelines' request list. Nothing is wrong; something is not yet shown.
Mapped, screened, nothing open, and every item on the request list present and graded. A request received today could be answered today.
Amber is not blue
'Indicator flagged' means you have something to do. 'Awaiting supplier evidence' means a supplier does. Collapsing the two would put work on your list that only someone else can close, and would bury the flags you can act on this week. They are different colours, carry different icons and are counted separately.
When a line lands in more than one state
- Decision match
- Indicator flagged
- Remediation open
- Awaiting supplier evidence
- Map incomplete
- Screened, file incomplete
- Evidence-ready
Several components feed one product line and their states can disagree. The platform does not average them. A decision match outranks everything: a published decision on one input takes the line to the top of the queue whatever the other inputs say. Below that, an open flag outranks a running plan, which outranks an outstanding request, which outranks a gap in the map. The screen shows the state and the component that produced it, so you can always see which input is driving the verdict.
Why ERWAY
The things this software deliberately will not do
You will be judged in a 30-working-day window on evidence you assembled beforehand, under Guidelines that say which kinds of evidence are worth little. That makes restraint a feature. Each of the following is something the platform could technically produce and refuses to, because producing it would create for you exactly the exposure you bought the software to avoid.
It does not generate a risk score
The Regulation defines no operator-side score and the Guidelines describe none. Inventing one would create a concept no authority will recognise, and would let a single decision match disappear into an average.
It does not treat a signed clause as evidence
The Guidelines say contractual clauses and supplier assurances are not sufficient on their own without follow-up and verification. The platform files them and grades them as asserted — never as closed.
It does not count a restricted audit as credible
Social audits conducted where workers cannot speak freely and access is restricted are, in the Guidelines' words, not credible evidence. Such an audit is graded accordingly, and the grade travels with it into the file.
It does not infer a tier it has not seen
Where the chain stops at tier two, the map says so. It does not fill tier three from a pattern seen in another supplier's chain, because the file has to survive an authority asking where each row came from.
It does not invent an obligation
The Regulation requires no due diligence, no audit and no report. The platform never says it does. It says what the Guidelines say: that what you did is what the authority will weigh.
It does not count down a clock that has not started
The 30 days, the 30 days, the 9 months and the 30 days are windows that open on events. Until the event, the display says 'not started', with the article that will start it.
It does not rewrite a past screening
Screenings are append-only and bind the sources and retrieval dates in force when they ran. When a database entry changes, a new screening is recorded — the old one still shows what you knew, and when.
It does not hide the legal basis behind a summary
Every state shows the article or Guidelines paragraph, the quoted words, the inputs used and the retrieval date. An authority asking why gets the whole chain, not a colour.
There is nothing to file — so the integration is where the map comes from
The Regulation gives an operator no form, no register and no API. The only submission it describes is the one you make when asked. So the integration layer points inward: at the supplier records and geolocations the EUDR product already holds, at the bills of materials and supplier data the PPWR product already holds, and at the ERP behind both. A company subject to all three regulations builds one map and reads it three ways.
EUDR plots and suppliers arrive as tier rows
Facilities geolocated for EUDR, legality evidence collected under it, and the questionnaires it sent are imported with their sources. The EUDR legality test already covers labour and human rights law, so part of the file is already written.
PPWR bills of materials become component shares
A packaging or product configuration broken down for PPWR already has weights and suppliers per component. The share column on the EUFLR line is derived from it, with the derivation shown.
ERP and PLM imports for the rest
Product lines, bills of materials, purchase orders and invoices come in by file or connector. Purchase records matter here: the Guidelines name them among the documents an authority may request.
Supplier portal, once per supplier
Suppliers answer in their own language through the same portal the other products use. A supplier with an EUDR or PPWR relationship sees one request list, not three.
Integrations we are not building
- A risk-score API — the Regulation defines no score to expose
- A compliance certificate or safe-harbour badge — none exists in the text
- A mirror of the Commission risk database — it is in development; we link, we do not copy
- Automatic disengagement from a flagged supplier — the Guidelines put it last, not first
- A submission connector to the Single Portal — operators do not file there; the public does
- Sanctions-list screening as a verdict — a listing is a signal, not a finding
None of these would produce output an authority would accept. Shipping them as though they would means putting your name under an assurance the Guidelines have already discounted.
See what a request for information would find in your file today
The tour follows one product line the whole way through — a cotton-blend workwear range sold by an EU importer, with a tier-3 spinning mill that the screening flags. No sign-up, and nothing to install.