Subject: Joint civil society and trade union letter on the Forced Labour Portal and implementation guidance under Regulation (EU) 2024/3015, 2 September 2026

We, the undersigned organisations, welcome the publication on 26 June 2026 of the preparedness package including the Forced Labour Portal and the guidance, which sets out the implementation process and obligations for authorities and companies under Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market. We view this guidance as a key building block in the EU's broader forced labour architecture.

This framework provides a solid foundation that could be further strengthened by addressing the following:

• The definition of forced labour and its indicators should be interpreted taking into account the social, economic and cultural context of the victim, reflecting the inherent case-specific nature of this exercise. Relatedly, we would caution against overreliance on the ILO forced labour indicators as a checklist to evaluate coercion and involuntariness. They should serve as a starting point for contextual analysis of how forced labour manifests and how it can genuinely be brought to an end, not as a substitute for it;
• In terms of the investigation procedure, future guidelines should:
  • Clarify further the need to avoid overreliance on results of social audits submitted by economic operators during the investigative process to demonstrate absence of forced labour...
  • Emphasize the importance of triangulating information submitted by economic operators during the investigative process through a tailored process that takes into account the risk of false compliance or worker coercion.
  • Highlight that actions to identify, prevent and remediate forced labour must be appropriate and effective to be considered as relevant in mitigating and/or remediating forced labour.
  • Ensure that Member States and the European Commission receive explicit capacity-building support and adequate financial and human resources for effective enforcement, including for the provision of adequate accompanying measures to economic operators, in particular SMEs (Art. 10).

We regret however, that the portal does not yet include a full list of Member States' competent authorities, even though EU Member States were required to designate one or more competent authorities by 14 December 2025.

Additionally, it does not include more detailed “guidance for economic operators on best practices for bringing to an end and remediating different types of forced labour” (Art. 11.b) nor on “due diligence in relation to forced labour imposed by state authorities” (Art. 11.f).

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