EU Forced Labour Regulation implementation guidance misses June 14 deadline

The European Commission's required Article 11 guidance packages — covering investigation procedures for competent authorities, due diligence expectations for economic operators, and complaint procedures for civil society — along with a public forced-labour risk database, were due June 14, 2026, but had not appeared as of late June, with no official explanation offered by the Commission. Enforcement of the underlying market prohibition does not begin until December 14, 2027, so compliance teams face uncertainty rather than immediate exposure, but the delay fits a broader pattern of slippage across EU supply-chain legislation, including the Deforestation Regulation and multiple CSDDD revisions. Counsel advising importers and multinational supply chains should note that the FLR's investigative framework already rewards documented, risk-based due diligence undertaken in advance of formal guidance — meaning clients should not wait for the guidance to begin mapping forced-labour exposure, updating supplier questionnaires, and aligning practices with the OECD Due Diligence Guidance and UN Guiding Principles, which the eventual EU guidance is expected to track closely.