European Union · Regulation (EU) 2024/3015

EU Forced Labour Regulation: find the exposure early

The regulation prohibits placing products made with forced labour on the EU market. When an authority asks what you knew about a supplier and what you did about it, the answer has to already exist. Libera helps you build that record continuously rather than retroactively.

A market-access rule, not a reporting rule

Regulation (EU) 2024/3015 prohibits placing on the EU market, and exporting from it, products made with forced labour. That makes it structurally different from reporting duties: the consequence lands on the product and the shipment, not only on a disclosure. Competent authorities can investigate and, where a prohibition is established, order withdrawal.

  • Applies to products, at any stage of production
  • Investigation is risk-based and can be triggered by submitted information
  • Authorities can request information from economic operators
  • The exposure is commercial as well as legal: inventory, orders, customers

Why the evidence question arrives suddenly

Under a market-access rule, the moment that matters is the information request. A company that cannot show what it knew about a supplier, when it knew it and what it did about it is reconstructing history under time pressure, usually while the goods sit still. The work that protects you is the work done before the request.

Where the risk usually sits

Forced labour concentrates in identifiable places: sectors with seasonal or subcontracted labour, countries with weak state response, workforces recruited across borders through intermediaries, and tiers below your direct supplier. Libera scores each of those dimensions explicitly and names them in the result, so a buyer can see why a node scored what it did.

  • Country prevalence and government response from Walk Free GSI 2023 (static edition)
  • Sector intensity informed by ILO estimates and US DOL TVPRA listings
  • Recruitment intermediaries treated as a distinct, named risk factor
  • Live screening against OFAC and the DHS UFLPA Entity List at the time of the check

Worker signals reach places paperwork does not

Supplier questionnaires describe what a supplier chooses to disclose. A confidential channel at the worksite can surface recruitment debt, withheld wages, retained documents or threats that never appear in a questionnaire. Libera keeps individual accounts confidential and shows management only aggregated indicator counts per site and supplier.

What an authority request looks for

Documentation that is contemporaneous, specific and consistent. Libera exports the screening history with dated scores and named factors, the aggregated signal record, the case timeline, remediation actions with owners and due dates, worker access verification status per site, and an immutable activity log.

What Libera does not claim

Libera does not determine whether a product was made with forced labour, does not represent you before an authority, and cannot prevent an investigation. It helps you see risk earlier and document a serious response.

How Libera maps to the workflow

From a screening score to a documented human decision.

01

Screen suppliers

Every supplier, site and labour provider is scored on country prevalence, government response, sector intensity, workforce size and use of recruitment intermediaries, then checked against official sanctions and import-ban lists at the time of the check.

02

Open and verify worker access

A QR poster at agreed access points opens a confidential reporting page in the worker's own language. Access can be verified through announced or unannounced checks by the buyer or an independent auditor, and the result is recorded per site.

03

Receive confidential signals

Workers report without a name, phone number, account or precise location. Management never reads an individual account; only aggregate indicator counts reach the console.

04

Detect patterns

Signals are clustered by site, supplier and ILO indicator, so a repeated pattern becomes visible even when each report on its own looks minor.

05

Human review

When signals accumulate, the supplier's risk status is raised and flagged for human review. Libera never concludes that forced labour occurred — a person decides what happens next.

06

Case and remediation

A case file records the investigation timeline, evidence register, remediation actions with owners and due dates, and the documented outcome.

07

Monitor and document

Re-screening, access re-verification and an immutable activity log produce an exportable record of what was found, what was decided and what was done.

What this page is not

This page summarises the purpose and shape of a regulation whose application arrangements, guidance and national enforcement structures continue to develop. It states no dates, thresholds or procedural steps, and it is not legal advice. Risk indicators produced by Libera do not establish that forced labour occurred in any supply chain.

Libera produces risk indicators for review. It does not determine that any company or person has committed an offence, does not guarantee compliance with any law, and is not legal advice. Every escalation requires human review.

Primary sources

Keep reading

See the risk before it becomes the story.

Screen suppliers, open a confidential worker channel, verify access, investigate patterns and document remediation in one workflow.