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The EU forced labour ban and what buyers will ask a supplier

A market prohibition with no size threshold, reaching non-EU manufacturers. Due diligence reduces investigation risk; it does not exempt a product.

Production line at a named manufacturing base
Name the plant. A trading address answers nothing.

The EU has banned products made with forced labour from its market. Not fined, banned: goods can be withdrawn and disposed of. It covers every product and sector, made inside or outside the EU, and it applies with no company size or turnover threshold. If you buy from Asia and sell in Europe, this is a question you will be asked long before it is enforced.

What the regulation does

Regulation (EU) 2024/3015 prohibits placing, selling or exporting products made with forced labour on the EU market. It entered into force on 13 December 2024 and applies fully from 14 December 2027, when investigations, market bans and the single submission point go live.

Two features make it different from the disclosure regimes buyers are used to. It applies to non-EU companies importing to or selling in the EU, so an overseas manufacturer is squarely inside its reach. And there is no size or turnover threshold, so it does not spare small importers the way reporting duties often do.

Due diligence is evidence, not a shield

This distinction is worth getting right, because it is widely misread. Due diligence under the regulation is voluntary. The Commission’s guidelines frame it as the mechanism that reduces the risk of being investigated: an operator who can show effective due diligence is a less likely target.

What it does not do is exempt a product. If forced labour is present, the ban applies regardless of how good the paperwork was. Due diligence is what you present to an authority, not a defence that survives the finding.

How this reaches a container supplier

Through the buyer, and earlier than the deadline suggests. Large EU purchasers are already writing supply chain requirements into contracts, and public buyers ask as a matter of course. In practice a supplier gets asked for:

  • Named production sites, not a trading address
  • Country of production for the specific run
  • Audit documentation for the plants
  • Visibility of the tier below: where the steel or the resin comes from
  • A policy position, and evidence it is applied rather than published

That last tier is where most container supply chains go dark, because a can maker knows its own plant and may not know its coil supplier. Saying so honestly is better than an assurance that cannot be evidenced.

The UK asks a different question

Great Britain has no equivalent import ban. The Modern Slavery Act 2015 requires qualifying businesses to publish an annual statement on steps taken to address slavery and trafficking in their supply chains. It is a transparency duty rather than a market prohibition, so a UK importer answers by reporting while an EU importer answers by not being able to sell. Two very different pressures on the same supply chain.

Where we stand on this

Directly, because a vague answer here is worse than none. We manufacture in Vietnam and China, and we name the production base for any order rather than hiding behind a Singapore contract address. Factory audit documentation is available in accordance with our UN certification, and we hold ISO 9001, ISO 14001, ISO 45001, which includes an occupational health and safety management system.

Upstream traceability below our own plants is scoped per programme rather than held as standard. Tracing and auditing steel and resin suppliers to the depth a rigorous due diligence programme expects is work with a cost and a lead time behind it, so we scope it against what your buyer actually requires instead of issuing a blanket assurance that would not survive a question.

Tell us what your customer is asking for and we come back with what we can evidence for your run: the named plant and its audit documentation as standard, and upstream tier mapping, supplier declarations or third-party audit at the coil and resin level where your programme needs it. If a requirement is beyond what we can evidence in your timeframe, we will say so at enquiry rather than at the point your buyer asks for the file.

Where to start

用途おすすめの缶選ぶ理由
Named production base 20L NATO Steel Fuel Can20L NATO規格 スチール燃料缶 Vietnam or China, stated per run.
Traceable material 20L Stainless Steel Water Can20L ステンレス給水缶 Mill certificate for the stainless grade.
Simplest supply chain Jerry Can Holders & Mountsジェリ缶ホルダー・マウント Fewest tiers behind the finished part.
Resin-based line Economy HDPE Jerrycan — non-UNエコノミーHDPEジェリ缶 — 非UN Where upstream visibility is hardest.

よくあるご質問

When does the EU forced labour regulation apply?

Regulation (EU) 2024/3015 entered into force on 13 December 2024 and applies fully from 14 December 2027, when investigations, market bans and the single information submission point go live. Buyers are writing the requirements into contracts well ahead of that date.

Does the EU forced labour ban apply to non-EU manufacturers?

Yes. It reaches non-EU companies importing to or selling in the EU, covers every product and sector whether made inside or outside the EU, and carries no company size or turnover threshold. Small importers are not spared the way they often are by reporting duties.

Does supply chain due diligence exempt a product from the ban?

No, and this is the most common misreading. Due diligence is voluntary and reduces the risk of being investigated, because an operator who can demonstrate effective due diligence is a less likely target. If forced labour is actually present the ban still applies. Due diligence is evidence to present, not a compliance shield.

What will a European buyer ask a container supplier for?

Named production sites rather than a trading address, country of production for the specific run, factory audit documentation, visibility of the tier below such as where the steel or resin comes from, and evidence that a policy is applied rather than merely published.

Does the UK have the same forced labour import ban?

No. Great Britain has no equivalent market prohibition. The Modern Slavery Act 2015 requires qualifying businesses to publish an annual statement on steps taken in their supply chains, which is a transparency duty. A UK importer answers by reporting; an EU importer answers by being unable to sell.

参考資料

The standards and regulations this page relies on, at their issuing body. Where a market rule is named here, check the current revision before you specify against it.

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