UK & EU Forced Labour Regulations: Preparing for 2027 & Beyond

As the Uyghur Forced Labor Prevention Act (UFLPA) approaches its fifth year of enforcement in the United States, forced labour regulation is gaining momentum across Europe.

A 2025 report from the UK Parliament's Joint Committee on Human Rights (JCHR) raised concerns the United Kingdom could become a destination for products produced through forced labour.

Investigations by human rights groups have already uncovered evidence of exploitative working conditions in factories providing goods destined for UK consumers.

As the calls for action grow louder, businesses will need to untangle complex supply chains to prove their goods are free of forced labour. Failure to prove will threaten their ability to operate in or sell into Europe and the UK.

In this article we examine the forces seeking to address forced labour, the regulations introduced from this, the implications for businesses, and how businesses can prove forced labour compliance.

Contents:

1. What’s behind the rise in forced labour?
2. Key forced labour regulations
3. Implications of forced labour laws for businesses
4. Proving forced labour compliance through science

1. What’s behind the rise in forced labour?

The scale of forced labour is revealed in some shocking statistics. Around 50 million people worldwide are living in situations of forced labour or human trafficking. This figure has increased 25% over the last decade.

Modern slavery is a growing risk across all industries, but particularly in sectors like textiles and apparel. An estimated one in five cotton garments globally may be tied to forced labour practices from China’s Xinjiang region.

These garments end up on the retail shelves of major global clothing brands, making unwitting consumers complicit in the trade of forced labour goods.

A report from the UK Parliament in 2025 determined that not enough was being done to prevent goods made with forced labour from entering the country. It found that the UK was importing approximately $26 billion in at-risk goods every year.

The severity and urgency of this issue has led to a strong regulatory response.

2. Key forced labour regulations

Many countries across the world have introduced forced labour regulations, most prominently the Uyghur Forced Labor Prevention Act (UFLPA) in the United States, but also Canada’s Modern Slavery Act, and similar legislation in Brazil, Mexico, Australia and New Zealand.

In Europe, strict new regulations and tougher enforcement of existing laws are set to enter force in the coming years.

EU Ban on Products Made with Forced Labour

The EU Ban on Products Made with Forced Labour will be enforced from December 2027. This regulation applies to all products made available in the EU market and sets penalties on businesses that fail to comply. If evidence of forced labour is found at any point in the supply chain, companies will be prohibited from trading in the market and ordered to withdraw the product.

UK Modern Slavery Act

The UK Modern Slavery Act has been in effect since 2015. It applies to companies operating in the UK with a turnover of over £36 million and requires companies to issue a modern slavery statement annually, reporting the steps taken to mitigate the risks of modern slavery in their supply chain. Companies may face court hearings for injunctions if they fail to comply with the requirements.

Despite this, the Forced Labour in UK Supply Chains report concluded that existing legislation is not meeting the Government’s ambition of zero forced labour in UK corporate supply chains. It advocates for changes to existing compliance requirements and import bans on goods associated with forced labour.

Corporate Sustainability Due Diligence Directive (CSDDD)

The EU Corporate Sustainability Due Diligence Directive will come into force from July 2027. It requires companies conducting business in Europe to identify and mitigate adverse environmental and social effects from both their own operations and those of supply chain partners. Failure to comply can result in financial penalties and being liable for damages caused.

ISO 37200: Managing the risk of modern slavery

The forthcoming ISO 37200 Draft International Standard aims to transform how business tackles modern slavery by providing guidance for the prevention, identification and response to human trafficking and forced labour. This framework is not a regulation but rather a standard which builds on a 2022 British Standard, and is designed to help organisations minimize forced labour risk without adding complexity or reporting burdens.

3. Implications of forced labour laws for businesses

What these regulations share is a requirement for businesses to meet thorough supply chain due diligence obligations – or face penalties if they do not comply.

For businesses, this means compliance is no longer a checkbox exercise but a fundamental shift in how supply chains are managed, audited and reported.

Expanding the scope of due diligence

Businesses must now look beyond their immediate Tier 1 suppliers. Due diligence must encompass both upstream (raw materials and production) and downstream (distribution and sale) partners.

This holistic approach ensures that companies aren't just cleaning up their own backyard while ignoring systemic abuses further down the line. If a component in your product was produced with forced labour three steps back in the chain, the legal and reputational risk sits squarely with you.

Verifying raw material sourcing

It’s no longer enough to take a supplier’s word at face value regarding where materials come from. Regulators are increasingly looking for substantiated proof of origin rather than just claimed origin.

This requires businesses to implement more rigorous verification processes, such as forensic origin verification, to ensure that compliant materials aren’t mixed with noncompliant materials, or that illegal practices such as fashion transshipments aren’t occurring.

Auditing product tracking and reporting

A critical implication of these laws is the need for a deep dive into internal tracking systems. Companies must assess whether their chain of custody reporting is genuinely accurate or if it relies on easily manipulated paperwork.

Falsified documentation is a risk of traditional traceability and businesses are susceptible in today’s complex global markets. Businesses need to verify that their digital or physical paper trails can withstand a forensic audit by authorities who are increasingly savvy at spotting inconsistencies.

Proactive remedial action

It’s important for businesses to have remedial action plans ready to go before a crisis hits. Rather than waiting for a regulatory seizure or media exposé, businesses are expected to identify vulnerabilities and fix them proactively.

By demonstrating a high standard of ethical behaviour and having clear protocols for addressing labour violations, a company can prove to regulators that it is a responsible actor, effectively protecting its ‘license to operate’ in a more scrutinized market.

4. Supporting forced labour compliance through science

To navigate the evolving forced labour landscape, businesses today must move beyond self-policing. They need evidence, not assumptions. The standard of "clear and convincing evidence" in regulations like the UFLPA demands objective proof.

Forensic science provides the means of determining the ‘ground truth’ by physically testing products and raw materials directly. This overcomes any potential for bias, inaccuracy or misrepresentation in paper or digital traceability tools.

Oritain uses advanced isotopic analysis and data science tools to verify the origin of products and raw materials. Because the environment imparts a characteristic and measurable chemical fingerprint on everything grown or reared in it, we can scientifically link a product through its chemical composition to its geographical origin

This assures manufacturers and suppliers that the materials they’re sourcing, and brands and retailers that the products they’re selling, aren’t tainted by forced labour.

Forensic science bypasses unreliable documentation, delivering objective evidence required to comply with forced labour regulations.

Global leaders in the cotton and textiles industry rely on Oritain’s forensic verification to protect their reputation and ensure market access. We don't just read the label – we verify the source.

By verifying the true origin of their products and raw materials, Oritain helps businesses successfully transform compliance risk into competitive advantage.