Regulation (EU) 2024/3015 prohibits products made with forced labour from being placed or made available on the Union market and prohibits their export. It covers products and components regardless of sector, origin, or whether they are produced inside or outside the Union. The Regulation generally applies from 14 December 2027; some provisions on authorities, the single portal and cooperation apply earlier.

1. Define the regulatory question first

The Regulation uses the definition of forced labour in ILO Convention No. 29 and includes forced child labour. Its concept of due diligence covers efforts by economic operators to identify, prevent, mitigate, bring to an end or remediate forced-labour risks connected with products for the Union market or for export. The framework is not a generic certificate scheme: the relevant question is whether a product was made with forced labour.

Assess the product, the operator’s role, the production locations, the supply-chain path and any Union-targeted distance sale together. Supplier documents may support the factual record, but a generic certificate or supplier statement cannot by itself prove that a product is outside the scope of an investigation.

2. Organise supplier evidence around the product

  • Product identity: product name, model/SKU, batches, components, raw materials, production sites, suppliers and relevant upstream nodes. Where useful, link commodity codes, purchase orders and shipments to the same product record.
  • Operators and transactions: legal names and addresses of manufacturers, importers, distributors and other relevant operators, together with contracts and transaction records. Do not substitute another company’s statement or another SKU’s file.
  • Labour-risk facts: production locations, recruitment and employment arrangements, wage and working-time records, freedom to leave employment, grievance channels, subcontracting and labour-intermediary information, and verifiable remediation records where relevant. Mark the source, coverage period and scope of each item.
  • Traceability: purchase orders, invoices, shipping documents, lot or batch identifiers, input-output records, supplier declarations and audit or site records where available. Keep version, date, owner and product linkage for every file.
  • Risk and action log: record risk indicators, prioritisation, preventive or mitigating actions, follow-up results and unresolved issues by location, process, material and supplier tier. A screening result should not be rewritten as “no risk” or “approved”.

3. Prepare for an information request

The Regulation provides for a risk-based assessment by competent authorities. Before a formal investigation, an authority may request information from economic operators or product suppliers about actions taken to identify, prevent, mitigate, end or remediate forced-labour risks. Where such a request is made, the Regulation provides a 30-working-day response period; the formal notice and applicable provisions govern the response.

A useful file should show which document supports which product, production site and period. Separate verified facts, supplier representations, missing evidence and disputed points. A certificate scan, generic social-compliance template or unlinked undertaking is not a substitute for a traceable factual record.

4. Keep public wording within the evidence boundary

Public copy may describe the product, documented supply-chain controls and the scope of available records. It should not say that the EU has approved the product, that forced-labour risk is zero, that detention is impossible, or that an investigation is guaranteed to end favourably. An unverified supplier statement should remain identified as an unverified statement, not become a company guarantee.

Recheck the product–supplier–batch link when a material, factory, subcontractor, supplier or production country changes. Commission guidance, risk indicators and competent-authority practice may be updated, so retain a version and review date for the evidence map.

5. Pre-submission questions

  1. Can the product, component, batch and production site be traced from sales or purchasing records to the supplier file?
  2. Does each material fact show its source, scope, date and responsible entity?
  3. Are facts, risk judgements, supplier representations and open items kept separate?
  4. Are preventive, mitigating, ending or remedial actions recorded rather than replaced by a single undertaking?
  5. Does the public wording state only supportable product and management facts, without presenting preparation as a regulatory result or certification conclusion?

Sources and boundary

This page is based on Regulation (EU) 2024/3015 (in particular Articles 3, 4, 8, 10–12, 17–21, 26 and 39) and the European Commission’s implementation guidance. It is a supplier-record reference for 绿色方舟（深圳）认证有限公司, not legal advice for a particular product, operator role or production site, and it does not predict an investigation outcome.