How does the EU Forced Labour Regulation (EU 2024/3015) affect Turkish suppliers?
The EU Forced Labour Regulation (EU 2024/3015) bans, from 14 December 2027, any economic operator regardless of size from placing on the EU market, making available or exporting products made wholly or partly with forced labour, so Turkish suppliers whose goods reach the EU must be able to show they manage forced labour risk in their own sites and subcontracting chains.
When does the EU Forced Labour Regulation apply?
The Regulation applies from 14 December 2027. It was adopted on 27 November 2024, published in the Official Journal on 12 December 2024 and entered into force the following day.
Some provisions already apply: preparatory articles such as the Commission’s duty to publish guidelines, the forced labour risk database and Member States’ notification of penalty rules have applied since 13 December 2024. Member States must notify the Commission of their penalty rules by 14 December 2026.
Who does the Regulation cover?
The Regulation covers every economic operator that places products on the EU market, makes them available or exports them from the EU: manufacturers, importers, distributors, retailers and online sellers. There is no exemption based on company size.
Scope is product-based: a product is covered if forced labour was used at any stage of its extraction, harvesting, production or manufacturing, in any tier of the supply chain, inside or outside the EU. According to the Commission’s guidelines, the size of the share made with forced labour does not matter. Services are excluded.
Even if a Turkish supplier is not itself an “economic operator” in the EU, the authority investigating a case may request information from manufacturers higher up the supply chain (“other product suppliers”).
What do the Commission guidelines say?
The Commission published its guidelines on applying the Regulation on 26 June 2026 as Commission Notice C(2026) 4386. The Regulation had set 14 June 2026 as the deadline. The guidelines are not binding, but they show how authorities will apply the Regulation.
They define forced labour by reference to ILO Convention No. 29 and list risk indicators: forced recruitment, deception, exploitation of debt, hazardous or degrading working conditions, onerous working hours, degrading living conditions, abusive additional obligations, physical or sexual violence, abuse of isolation, restrictions on movement, retention of cash, assets or identity documents, withholding of wages, threats or intimidation, and abuse of vulnerability.
The Regulation imposes no due diligence, audit or reporting obligation. However, the guidelines state that companies can submit due diligence documentation, corrective action plans and independent third-party audit reports as evidence during an investigation. There is an important caveat: social audits carried out where workers are under threat or constant surveillance, or where access to the site is restricted, are not considered credible.
How do investigations work?
- 01
Risk-based prioritisation
Authorities focus on the highest-risk products and areas, taking into account operators’ size and resources. The Commission leads where forced labour is suspected outside the EU; national authorities lead for their own territory.
- 02
Preliminary phase
The authority requests information from operators and, where relevant, other suppliers in the chain. Failure to cooperate can itself be treated as relevant evidence.
- 03
Investigation and decision
If forced labour is established, the product is banned from the market and from export; products not yet with end users are withdrawn and disposed of. The decision can be reviewed once the operator shows the forced labour has been eliminated.
What should Turkish suppliers do now?
Your EU customers will ask you for evidence they can use in an investigation. Before 14 December 2027:
- Map your supply chain: list every subcontractor workshop and main raw-material source.
- Make sure no identity documents, diplomas or bank cards are retained.
- Document that workers pay no recruitment fees, deposits or debts; if you use agents, review their contracts.
- Show that wages are paid in full, on time and through the bank.
- Show through records that overtime is voluntary and within the 270-hour annual cap of Turkish Labour Law No. 4857.
- Remove practices that restrict workers’ freedom to leave (withheld wages, penalties).
- Set up a grievance channel protected against retaliation, open to your workers and your subcontractors’ workers.
- Allow independent social auditors full site access and private interviews without management; otherwise the audit will not be considered credible.
- Appoint a person responsible for answering customers’ information requests on time.
Frequently asked questions
- Does the Regulation apply to SMEs?
Yes, there is no size exemption. Authorities do, however, consider an operator’s size and resources when prioritising cases and setting deadlines.
No. The guidelines say a violation will often be established through a combination of evidence types. Audit reports are one of them, alongside worker interviews, grievance records, payroll and traceability documents.
- Are products sold only in Turkey covered?
No. The Regulation covers only products placed or made available on the EU market or exported from the EU. If you are in the supply chain of a brand selling in the EU, your products may be covered.
- Does the Regulation require audits?
No. According to the Commission, the Regulation introduces no audit or reporting obligation; companies decide how to ensure their products are free from forced labour.