EU bans products made with forced labor

Key aspects

• The Corporate Sustainability Due Diligence Directive (“CS3D”) introduces corporate human rights and environmental due diligence obligations.
• Although these obligations apply only to companies meeting high employee and turnover thresholds, other European Union (“EU”) legislation refers to this standard of business conduct.
• In this context, the EU recently published Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labor (“Regulation” or “Forced Labor Regulation”). The Regulation extends the due diligence obligation to companies that place or make available on the EU market—or export from the EU—products made with forced labor.
• The Regulation also establishes an absolute prohibition on making these products available on the EU market.
• The Regulation will generally apply from 2027