Forced Labour Regulation

 

Managing labour risks in your supply chain

The Forced Labour Regulation (FLR) prohibits products made using forced labour at any point in the production chain. The regulation applies to all companies that place products on the EU market or export them, regardless of size or sector. Pantarein helps you identify the risks and put in place an approach that holds up under scrutiny.

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The FLR in practice

Implementation guidelines from the European Commission are expected by June 2026. The penalties are far-reaching: products may be stopped at the border or withdrawn from the market, even where your company has no direct involvement in the violation.

What does the FLR require?

  • Insight into working conditions at your suppliers, including those deeper in the supply chain
  • Risk-based prioritisation of high-risk sectors and countries
  • Documented follow-up of identified indicators of forced labour
  • A demonstrable due diligence approach that meets the requirements of enforcement authorities

Which businesses does the FLR affect?

  • All businesses that place products on the EU market or export them – the regulation has no turnover threshold
  • Importers and traders that source raw materials or semi-finished goods from high-risk countries or sectors
  • Manufacturers with complex, multi-tier supply chains and limited direct visibility of their sub-suppliers
  • Businesses that are already receiving questions from customers or auditors about working conditions in their supply chain

Our approach

Forced labour is rarely visible on the surface. An effective approach calls for a combination of sector knowledge, risk-based prioritisation and supplier engagement.

  • Risk analysis by sector and country – Drawing on international risk indicators (ILO, State Department, Global Slavery Index) and sector-specific information, we help you establish a well-founded risk assessment for your supplier base.
  • Supplier surveys and screening – We guide you in setting up targeted questionnaires and screening methods for suppliers in high-risk segments.
  • Mitigation and follow-up process – What do you do when you identify an indicator in your supply chain? We help you develop escalation paths, contractual safeguards and remediation procedures.
  • Documentation and governance – We help you put in place the right documentation, internal roles and periodic reassessment processes.
  • Software support – Together, we assess which tools can help you with supplier screening, risk registration and follow-up management.

What does it deliver?

  • Protecting market access: products linked to forced labour may be blocked or withdrawn – even without any direct involvement on the part of your company
  • Limiting reputational risk: demonstrable due diligence protects you when working conditions in your supply chain attract attention in the media or among the wider public
  • Meeting customer and tender requirements: major buyers and public authorities are increasingly making social due diligence a purchasing condition
  • Providing synergy with the CSDDD: a documented FLR approach forms an integral part of a broader CSDDD approach

Related services

  • Supplier risk mapping – Identifying labour and human rights risks by supplier and region.
  • Supplier engagement – Surveying, supporting and following up with suppliers.
  • Due diligence policy & governance – Embedding internal policy and processes.
  • CSDDD – Broader human rights and environmental due diligence across the value chain.

Take

 

the next step

Ready to manage labour risks in your supply chain?

The FLR applies to every business that places products on the European market. We help you establish an approach that is proportionate, remains workable and holds up under scrutiny.

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