The EU has held political talks on a law that will ban the sale on the EU market of products made with forced labour, as well as the export of such products from the EU.

On 22 January 2024, the EU Council and Parliament held negotiations to agree the final text of the regulation, the proposal for which was published by the EU Commission in September 2022. The Committee on International Trade and the Committee on Internal Market and Consumer Protection of the EU Parliament previously proposed its position on the regulation in October 2022 (here and here).

The restrictions will cover all types of goods, whether manufactured in or imported into the EU, which are wholly or partially made using forced (including child) labour. The scope of the proposed regulation is expected to only extend to the use of forced labour during products’ production, manufacture, harvest and extraction, and will not include service activities such as transport or distribution.

This ban will be largely structured through customs rules and screening, with customs authorities empowered to suspend the release for free circulation or export of products they identify as being in violation of the ban. Under the Parliament’s current proposal, companies established in high risk-areas or producing high-risk goods will need to demonstrate that they do not used forced labour to comply and any workers who are involved in forced labour will be due compensation, although the details of who will pay this and the legal mechanisms for remediation are to be decided. The Commission’s enforcement powers and authority to initiate investigations are also uncertain.

The Council has set a deadline for early February for consensus to be reached on the final text in order for the regulation to be adopted before summer.


Jessica Mutton's practice focuses on international trade, encompassing customs, tax evasion, sanctions and export controls, and anti-bribery. She joined Baker McKenzie from another global law firm in 2015. Jessica has knowledge of both the English common law and French civil law systems and has worked in London, Paris, Barcelona and Madrid. Jessica conducts training and presents at various seminars, webinars, and conferences on the complexities of international trade compliance. She is identified as a "rising star" by the Legal 500 and is recommended by the same body for her customs and Brexit work.


Olof Johannesson is a member of Baker McKenzie’s International Commercial & Trade Group in Stockholm. Prior to joining the Firm in August 2017, he worked at other law firms in Gothenburg between 2015 and 2017, and in Brussels between 2014 and 2015.


Johanna Asplund is an associate at the Firm’s London office in the Competition, Trade and Foreign Investment Practice Group. She completed her degree in International Relations from London School of Economics then a Graduate Diploma in Law and Legal Practice Course (LLM) from BPP University in 2019.