A ban on goods made with forced labor in the European Union has received final approval and will take effect in three years.
The new regulation allows the EU to prohibit the sale, import, and export of goods made using forced labor. EU member state authorities and the European Commission will be able to investigate suspicious goods, supply chains, and manufacturers, and the Commission will create a database of forced labor risk areas and products to support this work. Decisions to investigate will be based on factual and verifiable information and will be informed by risk factors such as the prevalence of state-imposed forced labor in certain economic sectors and geographic areas.
If a product is deemed to have been made using forced labor it will have to be withdrawn from the EU market and donated, recycled, or destroyed. Non-compliant companies may be fined. The goods may be allowed back into the EU once the company eliminates forced labor from its supply chains.
The regulation is expected to be published soon in the EU’s Official Journal and will enter into force the day after publication. EU member states will then have to start applying it within three years of the effective date.
Sandler, Travis & Rosenberg offers a comprehensive suite of services to help companies address forced labor concerns around the world, including supply chain reviews, due diligence strategies, and proactive remediation. ST&R also maintains a frequently updated web page offering a broad range of information on forced labor-related efforts in the U.S. and around the world. For more information, please contact ST&R at supplychainvisibility@strtrade.com.
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