On 14 December 2027, any product made with forced labour becomes illegal to sell in the European Union and illegal to export from it. Regulation (EU) 2024/3015 entered into force on 13 December 2024, and fashion brands that buy cotton and finished garments through multi-tier supply chains have about fourteen months left to build the evidence trail an authority will ask them for.
What the Regulation Bans
The Regulation prohibits placing or making available on the EU market, and exporting from it, any product made with forced labour. According to Hogan Lovells Cadwalader’s analysis of the Commission’s guidelines, the ban covers products made in whole or in part with forced labour, whatever share of the product the abuse touches, and it applies regardless of origin, sector or the stage of the value chain where the abuse occurred. A sweater knitted from yarn spun by a tainted mill falls inside the ban even when the dyeing and sewing happened under clean conditions.
Two scope points matter for fashion. Services fall outside the Regulation, so a forced labour problem at a logistics provider does not trigger it. Stock does not get grandfathered either. Goods sitting in a warehouse or distribution centre on 14 December 2027 remain covered, and only products that have already reached end users fall outside the rule.
How It Differs From the UFLPA
The United States already runs a forced labour import ban aimed at one region. The Uyghur Forced Labor Prevention Act creates a rebuttable presumption under Section 307 of the Tariff Act of 1930 that goods made wholly or partly in Xinjiang, or by entities on the UFLPA Entity List, involve forced labour and cannot enter the country. The importer must rebut that presumption to get its goods released, and the Entity List now names more than 100 companies.
Apparel sits at the centre of that enforcement. In the first months after the law took effect, CBP detained 631 shipments of apparel, footwear and textiles worth more than $29.5 million. From the start of fiscal year 2025 through April of fiscal year 2026, CBP detained 17,651 shipments under the UFLPA alone and denied entry to 10,959, and the agency continues to flag apparel and cotton as high-risk sectors. The value of those detentions has fallen, though. CBP data cited by the Wall Street Journal put UFLPA detentions at roughly $183 million in 2025, against about $1.4 billion in 2024. The US law also leaves gaps, and FLJ’s analysis of why Shein remains off the UFLPA Entity List shows how the de minimis carve-out for low-value shipments sits outside the ban.
The EU model works through investigations. A product can be prohibited only after a competent authority investigates it, with the Commission leading investigations into risks outside the EU and Member State authorities handling risks inside it. The ban also reaches beyond one region and one direction of trade, since it covers forced labour anywhere in the supply chain and applies to exports as well as imports.
How Enforcement Will Work
Authorities prioritise cases by the scale and severity of the suspected forced labour and by the quantity and value of the affected products. State-imposed forced labour ranks as a particular priority. Importers sit closest to enforcement, because they are the operators placing goods on the EU market.
The evidence standard is lower than in a criminal case. Authorities can draw on the Commission’s risk database, civil society and trade union reports, customs data, satellite imagery and isotopic testing. A company that cannot supply requested information gives the authority evidence of its own, because non-cooperation can support a finding of breach.
An adverse decision carries real cost. The authority must prohibit the product and order its withdrawal, and in principle its disposal at the operator’s expense. The prohibition applies to the product generally, so other operators cannot route the same goods through a different channel. Each Member State sets its own financial penalties and must notify its rules to the Commission by 14 December 2026.
Where Preparation Stands
The Commission published its non-binding guidelines in late June 2026, and the public forced labour risk database remains under development. Member States were due to designate their competent authorities by December 2025. Brands therefore know how investigations will run before they can see the database that will steer them.
What Brands Need Ready
The Regulation imposes no formal due diligence duty, and it also offers no safe harbour. A product can be prohibited even when its operator ran comprehensive policies and monitoring. Due diligence still matters in practice, because authorities ask for supply chain maps, bills of materials, purchase orders and customs records, and an inability to show traceability counts against the operator.
The Commission’s guidelines adopt the OECD six-step due diligence framework, which starts with integrating forced labour into company policies and risk systems and ends with providing or cooperating in remediation. Brands sourcing from regions with state-imposed forced labour face a particular problem, since social audits fail where workers cannot speak freely. The guidelines point those brands towards independent desktop research and ILO and civil society data, and they treat responsible disengagement as the only workable response where a supplier gives the brand no leverage.
Brands should also check existing inventory against the same standard, since the December 2027 date catches goods already in the warehouse.
Two Regimes, One Evidence Trail
The UFLPA blocks goods at the US border on the strength of a regional presumption. The EU Regulation prohibits products across the whole market after an investigation. A brand that can trace each garment back to its fibre source answers both, and a brand that cannot has fourteen months to start.
This article provides general information about the EU Forced Labour Regulation and the UFLPA and should not be taken as legal advice. Requirements and enforcement guidance continue to develop ahead of December 2027, and the right approach depends on your own supply chain. For advice on your specific situation, consult a qualified lawyer.
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