Regulation · Comparison
EUFLR, CSDDD, UFLPA and modern slavery acts: four different regimes
These laws are often discussed together, but they work in fundamentally different ways. Two are market-access bans on products, one is a corporate due diligence duty, and two are transparency obligations. Treating them as one 'forced labour compliance' requirement leads to the wrong preparation.
Published by Libera Europe · Last reviewed 5 October 2026
The short version
- EU Forced Labour Regulation (EUFLR) — a product ban. Products made with forced labour cannot be placed on, made available on, or exported from the EU market. Applies from 14 December 2027.
- CSDDD — a conduct duty. In-scope companies must carry out risk-based human rights and environmental due diligence across their operations and chains of activities.
- UFLPA — a US import presumption. Goods linked to Xinjiang or to entities on the UFLPA Entity List are presumed to be made with forced labour and barred unless the importer rebuts the presumption.
- UK and Australian Modern Slavery Acts — transparency duties. In-scope organisations publish an annual statement describing what they have done.
Side by side
| EUFLR | CSDDD | UFLPA | Modern Slavery Acts (UK / AU) | |
|---|---|---|---|---|
| Instrument | Regulation (EU) 2024/3015 | Directive (EU) 2024/1760, transposed nationally | US federal statute (2021), with Section 307 Tariff Act 1930 | UK MSA 2015 s.54; Australian MSA 2018 |
| Type | Market ban on products | Corporate due diligence duty | Rebuttable import presumption | Reporting / transparency |
| Applies to | Economic operators placing or exporting products, any size, any origin | Companies above thresholds set in the directive (amended since adoption) | Importers into the US | UK: commercial organisations with turnover ≥ £36m. AU: entities with consolidated revenue ≥ AUD 100m |
| Trigger | Risk-based investigation by competent authorities or the Commission | Ongoing obligation | Goods linked to Xinjiang or listed entities | Annual statement |
| Company audit/report duty? | No general duty; information may be requested during investigations | Yes — due diligence and reporting | Importer must provide evidence to rebut the presumption | Statement only; content partly prescribed |
| Main consequence | Withdrawal and disposal of products; penalties for non-compliance with decisions | Supervisory enforcement and civil liability per national law (subject to amendment) | Detention or exclusion of goods at the border | Reputational; limited direct penalties |
| Application | From 14 December 2027 | Phased; dates amended — check current text | In effect since 21 June 2022 | In effect |
What this means in practice
A single programme can serve all four, because they rest on the same practical foundation: knowing your suppliers, sites and labour providers; assessing risk by country, sector and recruitment model; giving workers a way to raise concerns; acting on what you find; and recording it. They differ in what is demanded of you and when.
- For EUFLR and UFLPA, the question is product- and supply-chain-specific: can you trace this product and show what you know about forced labour risk in its chain?
- For CSDDD, the question is whether your process is risk-based, ongoing and acted upon.
- For modern slavery statements, the question is whether you can describe that process honestly and show progress.
Where to go next
Detailed pages: EUFLR preparation, CSDDD, UFLPA screening, LkSG. For the shared foundation, start with the risk assessment method.
Sources and method
Compiled by Libera Europe from the official texts and government guidance linked below. Scope thresholds and dates are given only where stated in the primary source; the CSDDD in particular has been amended since adoption, so check the current consolidated text. This page is not legal advice and Libera does not determine whether any company is in scope of, or compliant with, any of these laws.
- Regulation (EU) 2024/3015 (EU Forced Labour Regulation) — EUR-Lex
- Directive (EU) 2024/1760 (CSDDD) — EUR-Lex
- US DHS — Uyghur Forced Labor Prevention Act
- US CBP — Forced labor enforcement (Section 307)
- UK Modern Slavery Act 2015, section 54 — legislation.gov.uk
- UK Home Office — Transparency in supply chains: statutory guidance
- Australian Government — Modern Slavery Act 2018
Libera produces risk indicators as prompts for human review, not findings. It does not determine that forced labour occurred, does not guarantee compliance with any law and is not legal advice.