Reuters: EU Forced Labour Regulation — Product Ban Clock Ticking for December 2027

A Reuters analysis published September 3 examined the EU Forced Labour Regulation (Regulation (EU) 2024/3015) and its interaction with the narrowed CSDDD framework. From December 14, 2027, no product made with forced labour may be placed on or exported from the EU market — a ban covering all products regardless of origin, applying to all companies with EU market access. The Commission launched its preparedness package and Single Portal on June 30, 2026, providing compliance guidelines and a risk database identifying high-risk geographic areas and product categories. The Reuters analysis noted that the product-ban mechanism gives the Forced Labour Regulation "belt and braces" effect relative to the CSDDD's due-diligence obligations, which were narrowed significantly in the Omnibus I simplification. The Jones Day analysis of the Commission's June 26 guidelines characterized them as "mandatory due diligence in disguise" — requiring companies to demonstrate supply-chain mapping and risk identification processes that effectively replicate CSDDD-level diligence even for companies exempted from that directive's scope.