The Forced Labour Regulation: Is the Commission’s proposal the best solution?

amfori strives for sustainable supply chains with minimal social and environmental impact. Therefore, we support the prevention of products made from forced labour being sold in, and from, the EU. The proposal has many positive elements, but this paper offers some suggestions for improvements.

amfori key recommendations

1. The term “state imposed forced labour” should be included with “forced labour”.
2. Submissions under Article 4(1)(a) may refer to allegations of forced labour against a factory (or group of factories) making a range of products, and refer to a geographic region.
3. The Commission should act as a competent authority.
4. The time limit for economic operators to respond to in the preliminary phase of an investigation should be extended to 30 days.
5. The initiation of a preliminary and actual investigation should be published on the dedicated website of the relevant competent authority on the day of initiation. The conclusion of those investigations should also be published in detailed form.
6. Competent authorities should issue a detailed response to submissions alleging forced labour within 30 days.
7. Investigations should be concluded no later than 90 days after initiation.
8. Economic operators should comply with an order to withdraw products from the market within 90 days.
9. The EU should provide particular assistance to companies encountering SIFL within their supply chain and the guidelines should include the means for companies to access that aid.
10. The Database and Guidelines should be published before the Regulation enters into force.
11. Confidentiality should be applied automatically to victims of, or associated with, instances of forced labour who make submissions in that regard.

Contact person

For more information, please contact Stuart Newman, Senior Legal Advisor – Sustainable Trade & Customs