Jones Day's analysis (July 28) of the European Commission's June 26 Forced Labor Regulation guidelines is the week's most operationally significant compliance document for supply chain counsel. The EU FLR imposes what the Guidelines describe as an "obligation of result" — an unconditional and absolute duty that no product placed on the EU market has been produced with forced labor at any stage of
The EU Deforestation Regulation (EUDR) — which requires operators to ensure commodities are produced without link to newly cleared forests — has been postponed again, with the European Commission citing that "businesses and partner countries need more time to prepare the new supply chain traceability system." The Commission has also proposed exempting some beef products from the regulation's scope
A UK House of Lords Private Members' Bill introduced June 17, 2026 would impose mandatory human rights and environmental due diligence on commercial organisations with annual turnover of £36 million or more. Modelled on the Bribery Act 2010's "failure to prevent" structure and broadly mirroring the EU CSDDD, the bill includes civil liability for value-chain harms, financial penalties of up to 10%
The European Commission's public consultation on CSDDD implementation guidelines closes today, July 24, 2026 (midnight Brussels time). The consultation covers how companies should conduct due diligence, use data sources, and apply digital tools. First-tranche guidelines are due by July 26, 2027; second-tranche guidelines by July 26, 2028. The amended CSDDD — scope now limited to companies with 5,0
The European Commission published detailed implementation guidelines for the EU Forced Labour Regulation (FLR) on June 26, 2026. The headline rule is unambiguous: products made using forced labour at any point in the supply chain — any tier, any jurisdiction — cannot be placed on the EU market. There are no country exemptions, no industry exemptions, and no minimum threshold. The guidelines flag t
U.S. Customs and Border Protection issued comprehensive Forced Labor Enforcement Operational Guidance for Importers on June 12, superseding the prior 2022 UFLPA guidance. The 79-page document consolidates CBP's enforcement framework under three legal authorities — the Uyghur Forced Labor Prevention Act, the Countering America's Adversaries Through Sanctions Act, and the general forced labor import
The European Commission launched a consultation on draft implementation guidance for the Corporate Sustainability Due Diligence Directive this week, following the Omnibus I amendments that fundamentally reshaped the directive's scope and obligations. The Omnibus I package, which entered into force on March 18, 2026, reduced the CSDDD's scope by approximately 70% — to companies with over 5,000 empl
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. Enforcemen
The Commission opened a stakeholder consultation on June 14 seeking input to shape the implementation guidelines for the Corporate Sustainability Due Diligence Directive, covering due diligence processes, stakeholder engagement, and penalties, with a response deadline of July 24, 2026, ahead of planned guideline adoption in Q1 2027. The questionnaire specifically invites comment on which scoping t
The European Commission launched a consultation running to July 24, 2026, seeking stakeholder input on implementation guidelines for the Corporate Sustainability Due Diligence Directive following its modification by Omnibus I. The guidelines are intended to address voluntary model contract clauses, due diligence processes and risk factors, digital tools, data sources, third-party verification, and
Effective June 29, 2026, Section 250 of the UK's Crime and Policing Act 2026 (CPA) replaced the Economic Crime and Corporate Transparency Act 2023's senior manager provisions with a far broader regime: companies incorporated anywhere in the world are now criminally liable for any UK criminal offence committed by a "senior manager" acting within the actual or apparent scope of their authority. Crit