Executive summary

On 26 June 2026, the European Commission adopted new Guidelines on the application of Regulation (EU) 2024/3015 prohibiting products made with forced labour on the Union market.

The Regulation will apply from 14 December 2027 and prohibits products made with forced labour from being placed or made available on the EU market or exported from the EU.

Although the Regulation applies across sectors, it is particularly relevant for technology companies with complex global supply chains, including businesses operating in electronics, semiconductors, telecommunications equipment, batteries, connected devices, advanced manufacturing and other hardware-intensive industries.

Importantly, the prohibition applies where forced labour has been used at any stage of extraction, production or manufacturing, including in relation to components and raw materials. Whether the prohibition applies does not depend on the proportion of the product affected by forced labour.

The Commission has also scheduled sector-focused implementation work for electronics and semiconductors, alongside other high-complexity sectors. That work is part of the Commission’s preparedness programme and does not create a separate legal regime for those industries.

A product-based prohibition

The Forced Labour Regulation differs from traditional corporate due-diligence legislation.

It creates an obligation of result: economic operators must ensure that products made with forced labour are not placed or made available on, or exported from, the EU market.

The Regulation does not itself impose a general mandatory audit or reporting system and does not prescribe a specific due-diligence process. Article 1(3) confirms that it does not create additional due-diligence obligations beyond those already provided for in Union or national law.

However, the Guidelines make clear that appropriate due diligence may substantially assist businesses in identifying, preventing and mitigating forced-labour risks and in demonstrating to authorities how those risks have been addressed.

Components can affect the entire technology product

For technology businesses, one of the most important aspects of the Regulation is its application to complex supply chains.

A product falls within the Regulation where forced labour has been used in whole or in part at any stage of its production or supply chain.

This may therefore capture risks relating to:

• semiconductors and electronic components;
• critical minerals and raw materials;
• batteries and battery materials;
• displays, sensors and communications modules;
• circuit boards and other electronic assemblies;
• hardware incorporated into connected products;
• telecommunications and networking equipment; and
• components sourced through multi-tier international supply chains.

The Guidelines expressly clarify that the Regulation applies regardless of the size of the share or part of the product produced using forced labour. The relative physical, functional or economic significance of an affected part may, however, influence how authorities prioritise investigations.

Supply-chain visibility becomes important

Competent authorities will apply a risk-based approach when deciding whether to investigate suspected forced-labour risks.

Technology businesses may therefore need to understand not merely their immediate suppliers but also relevant upstream manufacturing, processing and sourcing relationships.

During an investigation, authorities may request information concerning the measures an economic operator has taken to identify and address forced-labour risks.

The Guidelines consequently make supply-chain mapping, supplier engagement and documented due diligence increasingly important from an enforcement perspective, even though the Regulation itself does not impose a separate general due-diligence obligation.

What happens if forced labour is established?

Where the competent authority determines that a product has been made with forced labour, it may require the economic operator to:

• stop placing or making the product available on the EU market;
• withdraw affected products that remain on the market;
• remove affected products from online interfaces;
• dispose of affected products or components; and
• prevent their export from the EU.

Products already sold to end users are generally not subject to the withdrawal obligation.

For technology products containing a replaceable component affected by forced labour, the Regulation may allow that component to be removed and replaced with a compliant component instead of requiring destruction of the entire product. If the operator does not replace the affected part, the entire product may still have to be disposed of.

This distinction may be particularly significant for high-value electronics, machinery and other complex technology products.

Special treatment for strategic and critical technologies

The Guidelines also recognise the particular consequences that enforcement may have for products forming part of supply chains of strategic or critical importance to the EU.

In appropriate circumstances, the competent authority may require affected products to be withheld temporarily rather than immediately disposed of, allowing the economic operator time to eliminate the forced-labour issue.

When determining strategic or critical importance, authorities may take into account EU policy concerning critical technologies, critical raw materials and net-zero technologies.

This may be particularly relevant for semiconductors, advanced technologies, critical components and other strategically important technology supply chains.

Online sales are also covered

Technology companies selling products directly into the EU should also note that the Regulation is not limited to traditional imports.

Products offered through online or other distance-sales channels fall within the Regulation where the offer is targeted at EU end users.

Relevant indicators may include delivery options into the EU, local languages and currencies, payment methods and EU-related domain names.

What technology businesses should do now

Map critical supply chains.

Identify important components, materials, manufacturing locations and higher-risk upstream suppliers.

Review supplier due diligence.

Assess whether current onboarding, monitoring and escalation procedures adequately address forced-labour risks.

Review contractual protections.

Consider appropriate supplier representations, information rights, audit mechanisms, remediation obligations and termination or disengagement provisions.

Identify high-risk components.

Particular attention may be appropriate for semiconductors, electronics, batteries, critical minerals and other components sourced through complex international supply chains.

Improve traceability.

Businesses should be able to identify where critical products and components originate and how they move through the supply chain.

Prepare an investigation response process.

Responsibility for responding to authorities should be allocated internally and relevant supply-chain evidence should be accessible.

Consider product architecture.

For high-value technology products, the ability to identify and replace individual affected components may become relevant to the consequences of an enforcement decision.

Coordinate regulatory compliance.

Forced-labour controls should be considered alongside sanctions, export controls, customs rules, the Corporate Sustainability Due Diligence framework and other applicable supply-chain requirements.

FAQ

When does the EU Forced Labour Regulation apply?

The prohibition becomes applicable on 14 December 2027.

Does the Regulation apply specifically to technology companies?

It applies to all sectors and products. However, complex international technology supply chains may create particular exposure. The Commission has included electronics and semiconductors in its sector-focused implementation programme; that does not create a separate legal regime for those sectors.

Does the Regulation impose mandatory supply-chain due diligence?

Not as a standalone obligation. The Regulation establishes an obligation to ensure that products made with forced labour are not placed on or exported from the EU market. The Guidelines nevertheless recognise due diligence as an important means of identifying and addressing forced-labour risks.

Can a problem with one component affect an entire product?

Yes. The Regulation can apply where forced labour has been used in producing only part of a product, regardless of the relative size or value of that part.

The size or significance of the affected part may still be relevant to how authorities prioritise investigations.

Where the affected component is replaceable, it may in certain circumstances be possible to remove and replace that component rather than dispose of the complete product.

Can products be withdrawn from the EU market?

Yes. Products found to have been made with forced labour may be prohibited, withdrawn and, where applicable, disposed of. Customs authorities may also prevent affected products from entering or leaving the EU market.

Does the Regulation apply to online sales from outside the EU?

Potentially yes. Products offered online are covered where the offer is targeted at end users in the EU.

Sources

• European Commission, Guidelines on the application of Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market, C(2026) 4386 final, 26 June 2026.
• Regulation (EU) 2024/3015 of the European Parliament and of the Council of 27 November 2024 on prohibiting products made with forced labour on the Union market.
• European Commission, Forced Labour Single Portal.
• European Commission, implementation materials concerning the Forced Labour Regulation.