Lobbying on Effectively banning products produced, extracted or harvested with forced labour

Effectively banning products produced, extracted or harvested with forced labour

Single market

The initiative will aim at effectively prohibiting making available products made, extracted or harvested with forced labour on the EU market, whether they are made in the EU or elsewhere in the world.

Links

Public consultation

ID: 13480

Lobbying Activity

103 responses

BusinessEurope seeks clarity on forced labour ban implementation

BUSINESSEUROPE, 30 Nov 2022

The organization requests clarification on how the forced labour regulation relates to other EU initiatives, especially the Corporate Sustainability Due Diligence Directive. They want longer timelines for companies to provide evidence and withdraw products, and earlier publication of implementation guidelines.

This would reduce duplications and administrative burden for companies already complying with due diligence requirements.

Workers in high-risk countries may lose protection if companies withdraw from those markets.

Business lobby seeks sector-specific approach over blanket forced labour ban

BUSINESSEUROPE, 20 Jun 2022

BUSINESSEUROPE requests recognition of existing company efforts and sectoral schemes rather than one-size-fits-all regulation. They call for a thorough impact assessment before proceeding and want clear coordination with upcoming due diligence legislation to avoid duplications.

This would allow them flexibility to use existing voluntary initiatives rather than new compliance requirements.

Workers subjected to forced labour lose stronger protections against exploitation in supply chains.

ETUC demands comprehensive EU ban on forced labor products

EUROPEAN TRADE UNION CONFEDERATION, 20 Jun 2022

The ETUC demands including transported goods and removing exemptions for small businesses. They call for bans targeting specific production sites or transport vessels.

This proposal strengthens collective bargaining and empowers unions to enforce fundamental rights.

Importers using forced labor will face product seizures and deterrent financial fines.

AmCham EU urges clearer rules for forced labour ban

American Chamber of Commerce to the European Union, 30 Nov 2022

AmCham EU requests alignment with sustainability laws and longer investigation response timelines. They advocate for harmonized enforcement and recognition of industry compliance schemes.

Standardized rules and extended deadlines would reduce the risk of internal market fragmentation.

Vulnerable communities could suffer if companies suddenly withdraw from regions identified as high-risk.

AmCham EU urges risk-based approach to forced labour ban

American Chamber of Commerce to the European Union, 20 Jun 2022

AmCham EU requests a risk-based approach aligned with international standards and industry verification schemes. They urge authorities to avoid product-specific data requests and allow companies to respond before enforcement.

Harmonized rules would prevent costly market fragmentation and simplify compliance for multinational businesses.

Workers in high-risk regions may suffer if companies irresponsibly disengage to avoid regulatory risks.

German industry urges delay and alignment for forced labor ban

Bundesverband der Deutschen Industrie e.V., 30 Nov 2022

BDI requests the ban be implemented only after digital databases and guidelines are fully operational. They argue for alignment with due diligence laws to prevent doubled compliance burdens. They also insist that the burden of proof must remain unreversed.

Aligning regulations would allow businesses to meet high standards at the lowest costs possible.

Exploited workers remain unprotected while the industry pushes to delay effective enforcement mechanisms.

EuroCommerce backs forced labour ban while seeking clearer rules

EuroCommerce, 30 Nov 2022

The group requests clear investigation timelines and alignment with the Corporate Sustainability Due Diligence Directive. They suggest extending deadlines for businesses to prepare and providing guidance on submission procedures.

Clearer rules would prevent retailers from facing excessive administrative burdens and time-consuming proof requirements.

National authorities and companies may waste resources investigating unsubstantiated complaints instead of actual violations.

Retailers urge market-based measures for EU forced labor ban

EuroCommerce, 20 Jun 2022

The group prefers market measures over customs stops and demands clear decision timelines. They request consistency with existing due diligence rules and exemptions for small enterprises.

Limiting liability to wilful negligence and exempting small businesses reduces overall compliance costs.

Human rights advocates lose a powerful mechanism for holding companies strictly accountable.

DIGITALEUROPE urges component-level focus in forced labour product ban

DIGITALEUROPE, 30 Nov 2022

The group requests harmonizing rules with other laws and extending investigation timelines. They also suggest recycling non-compliant components instead of destroying entire products.

Limiting disposal to specific parts prevents the wasteful destruction of entire devices.

Vulnerable workers may suffer if fragmented national rules make corporate compliance less effective.

DIGITALEUROPE Urges Risk-Based Approach to Forced Labour Ban

DIGITALEUROPE, 20 Jun 2022

DIGITALEUROPE requests a risk-based approach aligned with international standards and existing sustainability laws. They suggest a transparent process with clear evidence thresholds and a gradual ramp-up for enforcement. The group also wants recognition for existing industry-led due diligence schemes.

This would lower compliance costs by allowing companies to use existing industry standards.

Victims of forced labour may face delayed justice due to proposed enforcement ramp-up periods.

SMEunited warns forced labour ban threatens small business survival

SMEunited aisbl, 30 Nov 2022

SMEunited demands a mandatory impact assessment and an SME test before adopting the regulation. They insist public authorities should prove violations rather than burdening small business owners. Supporting tools must also be operational before any enforcement begins.

This would shield small businesses from facing disproportionate sanctions for unknown supply chain violations.

National authorities would bear the full administrative burden and cost of investigating complex supply chains.

SMEunited demands realistic forced labour rules for small businesses

SMEunited aisbl, 20 Jun 2022

Legislation must include public authorities as fighting forced labour exceeds the power of entrepreneurs. Existing guidelines are not adapted for small businesses and lack a reality check.

SMEs would avoid being tasked with complex site inspections they cannot perform.

Public authorities would bear more responsibility if enforcement duties are not privatised.

Consultation response

EPIA SolarPower Europe, 30 Nov 2022

Please find attached SolarPower Europe's position paper on the forced labour product ban.

SolarPower Europe urges manageable enforcement of forced labour ban

EPIA SolarPower Europe, 20 Jun 2022

The association requests that authorities focus scrutiny on known risk areas and exempt companies with existing auditing systems. They suggest a sample-based review process for imports to avoid excessive bureaucracy. Finally, they demand that the regulation avoids retroactive measures or confiscation of installed products.

A targeted approach reduces administrative burdens and protects current solar infrastructure investments.

Forced labour victims may face continued risks if authorities only review import samples.

German trade unions urge EU ban on forced labor products

Deutscher Gewerkschaftsbund, 8 Jun 2022

The DGB supports banning products made with forced labor and demands trade union involvement. They suggest using technical methods to track product origins in authoritarian states.

This would ensure fair competition and protect labor standards throughout global supply chains.

Businesses exploiting workers through forced labor will be barred from European markets.

Swedish industry urges clarity on EU forced labour ban

Confederation of Swedish Enterprise, 30 Nov 2022

The group demands a full impact assessment and insists that authorities carry the burden of proof. They also request detailed guidelines at least one year before the ban begins.

It ensures companies avoid massive administrative burdens and preserves the presumption of innocence.

Developing nations risk being cut off from trade due to high compliance costs.

Swedish Enterprise urges risk-based bans on all forced labour products

Confederation of Swedish Enterprise, 20 Jun 2022

The organization calls for a product withdrawal mechanism covering all goods rather than just an import ban. They insist that public authorities, not companies, must prove forced labour has occurred before withdrawing products.

Shifting the burden of proof to authorities avoids huge costs for legitimate businesses.

Public authorities face high costs as they must find and prove forced labour.

IndustriAll Europe demands total EU ban on forced labor products

industriAll European Trade Union, 20 Jun 2022

The union demands the ban cover all countries, sectors, and companies without exceptions for size. They advocate for a traffic light system to flag high-risk sectors and a transparent complaints process. They insist trade unions must be involved in monitoring and remediation.

The proposal protects union members from unfair competition by goods produced under abusive conditions.

Exploitative producers face product seizures and costly remediation before their goods enter the single market.

FoodDrinkEurope urges alignment of forced labour and due diligence laws

FoodDrinkEurope, 30 Nov 2022

FoodDrinkEurope advocates aligning this regulation with other directives to prevent overlapping requirements. They request harmonized guidance and clear definitions to ensure legal certainty for food businesses. They also call for a risk database to support smaller companies with administrative burdens.

This alignment would lower compliance costs by allowing companies to reuse existing due diligence processes.

Non-EU suppliers may face trade bans or costly customs delays that disrupt market access.

Austrian chamber calls for limited liability in labor bans

Wirtschaftskammer Österreich, 15 Jun 2022

The group argues that labor standards are a public responsibility for states to enforce. They propose a simple declaration system where importers are not liable for supplier non-compliance.

This would lower compliance costs and protect businesses from legal penalties.

Consumers would face reduced choices and less competition for certain goods.

Eurometaux urges harmonised approach for EU forced labour ban

EUROMETAUX, 30 Nov 2022

Eurometaux calls for a harmonised approach with existing industry standards to avoid bureaucracy. They request clear product categories and time to remedy violations before products are banned.

This alignment would reduce compliance burdens and protect mining investments in high-risk regions.

Vulnerable workers could suffer if responsible companies withdraw and are replaced by lower-standard firms.

Eurometaux urges alignment of forced labour ban with existing rules

EUROMETAUX, 20 Jun 2022

Eurometaux requests the new ban be aligned with existing supply chain rules to ensure consistency. They also seek clear guidance for businesses on compliance and enforcement.

Alignment would reduce regulatory complexity and protect the industry from excessive compliance costs.

Conflict-affected regions may lose vital investment if companies flee to avoid regulatory risks.

CLEPA urges EU to scrap forced labour product bans

European Association Automotive Suppliers, 14 Nov 2022

CLEPA requests that the EU focus on improving working conditions rather than banning products. They propose deleting requirements to dispose of existing goods and allowing companies a one-year window to fix supply chain issues.

This approach would protect automotive suppliers from massive disposal costs and prevent sudden disruptions to global supply chains.

Environmental efforts are harmed as the policy could lead to the wasteful destruction of thousands of car components.

MedTech Europe Urges Global Alignment on Forced Labour Ban

MedTech Europe, 20 Jun 2022

They advocate for a risk-based approach and global alignment to ensure rules remain achievable. The association also stresses providing adequate support for small businesses within complex medical supply chains.

Global coordination would reduce compliance costs for manufacturers managing highly complex, multi-tiered supply chains.

European Transport Workers' Federation urges EU ban on forced labour fish

European Transport Workers' Federation, 17 Jun 2022

The ETF requests a ban on fish products linked to labour abuses and forced labour. They suggest implementing measures similar to illegal fishing regulations and enforcing international social standards. The group also emphasizes monitoring exploitation occurring within or near European borders.

A ban would protect legitimate fisheries workers' interests from competition based on exploitation.

Exploitative vessel owners and recruitment agencies will lose access to the EU market.

Fortum demands legal certainty in EU forced labour ban

Fortum Oyj, 29 Nov 2022

Fortum argues that authorities must carry the burden of proof using objective evidence. They want the right to review decisions before customs are notified. Furthermore, penalties should be proportionate and not linked to company turnover.

This would minimize administrative costs and prevent legal risks from vague regulations.

Civil society groups and whistleblowers may face higher barriers when reporting suspected abuses.

Danish Chamber of Commerce favors existing due diligence rules

The Danish Chamber of Commerce, 20 Jun 2022

The Chamber finds that forced labor has already been addressed in the CSDD-proposal. They recommend that an adequate impact assessment is of utmost importance. They also cannot support a marketing ban.

This would avoid new administrative burdens and shield retailers from legal liability.

Forced labor victims lose immediate protection if impact assessments delay new enforcement rules.

German employers demand SME exemptions in forced labor ban

Bundesvereinigung der Deutschen Arbeitgeberverbände e.V., 28 Nov 2022

The group wants small businesses exempted and the state to handle product removal. They also demand judicial review and clearer evidence standards for enforcement decisions.

These changes would reduce legal risks and compliance costs for German companies.

National governments and taxpayers would face higher costs for enforcing product recalls.

German employers warn against regulatory duplication in forced labor ban

Bundesvereinigung der Deutschen Arbeitgeberverbände e.V., 20 Jun 2022

The BDA calls for a simplification of reporting duties and the exclusion of products originating within the European Union. They emphasize the need for a full impact assessment to avoid bureaucratic overload.

This would lower operational expenses and prevent the disruption of established trade frameworks.

Vulnerable workers in Europe lose protection if products made within the EU are excluded.

European Brands Call for Coherence in Forced Labour Ban

AIM - European Brands Association, 30 Nov 2022

AIM calls for alignment with due diligence laws and a 12-month adaptation period. They insist that national authorities must carry the burden of proof when investigating.

Unified standards would prevent legal uncertainty and lower administrative costs for brand manufacturers.

Responsible companies in high-risk areas could suffer from broad, region-wide product bans.

AIM urges aligned EU rules for forced labor product ban

AIM - European Brands Association, 20 Jun 2022

AIM demands that new rules align with the Corporate Sustainability Due Diligence Directive for legal certainty. They stress that implementation guidance is essential and responsibility must lie with the first importer.

Clearer rules would prevent extra administrative burdens and duplication of compliance costs across member states.

Producers in high-risk areas may face penalties from blanket bans without actually improving human rights.

German chemical industry association urges focus on immediate suppliers

Verband der Chemischen Industrie e.V., 20 Jun 2022

VCI requests an impact assessment and limiting rules to immediate suppliers. They believe the ban needs existing due diligence frameworks.

Limiting checks to direct suppliers would reduce administrative burden and compliance costs.

Workers in lower supply chain tiers lose protection if oversight stops at Tier 1.

German steel industry urges EU to scrap forced labor ban

Wirtschaftsvereinigung Stahl, 20 Jun 2022

WV Stahl requests the EU drop the initiative to avoid overregulation. They also want the steel industry excluded because it provides intermediate products.

This would prevent regulatory overlap and protect the industry from double penalties.

European manufacturers lose access to essential materials if those inputs are banned.

ECCJ demands EU forced labor ban include victim remediation

European Coalition for Corporate Justice, 20 Jun 2022

The coalition requests a binding law that applies to all companies regardless of size. They demand that lifting trade bans be strictly contingent on providing compensation to victims. Companies should also be forced to publicly map their entire supplier networks.

This proposal would establish the mandatory corporate accountability and victim restitution the group advocates for.

Businesses with opaque supply chains would face product recalls and public shaming through sanctions lists.

German retail association warns of bureaucratic overload from labor ban

Handelsverband Deutschland, 20 Jun 2022

The association requests specific EU guidance for high-risk regions and simplified reporting rules. They argue responsibility should be limited to private labels due to supply chain complexity.

Restricting liability to private labels would significantly reduce administrative burdens and logistical costs.

Vulnerable workers might face increased danger if companies cannot implement safe remedial measures.

Anti-Slavery International urges worker-centered forced labour ban

Anti-Slavery International, 30 Nov 2022

The organization calls for a regulation that prioritizes worker remediation and addresses state-imposed forced labour. They recommend mandatory mapping of supply chains and the implementation of region-wide bans for systemic human rights abuses.

The proposed changes would provide the organization with more effective legal tools to eliminate global slavery.

Companies would lose the ability to use social audits as a shield to prevent forced labour investigations.

Anti-Slavery International urges EU to ban all forced labour goods

Anti-Slavery International, 20 Jun 2022

The group calls for an instrument covering all companies and logistics services. It demands a border mechanism to stop suspected goods before they reach consumers. Prohibitions should only be lifted after victims receive compensation and remedy.

Successful implementation would directly achieve the organization's primary objective of ending global slavery.

Exploitative businesses and states would lose lucrative market access and face financial penalties.

Independent Retail Europe urges efficient enforcement of forced labour ban

Independent Retail Europe (formerly UGAL - Union of Groups of Independent Retailers of Europe), 30 Nov 2022

The group wants investigations to target central organizations rather than individual small retailers. They also request longer response times and the ability to donate seized goods.

Targeting central organizations would reduce administrative costs and burdens for individual retailers.

Delayed customs enforcement may permit products made with forced labour to enter circulation.

Clean Clothes Campaign demands comprehensive EU forced labour ban with transparency requirements

Clean Clothes Campaign / Stichting Schone Kleren Kampagne, 20 Jun 2022

The organization requests a binding legal instrument covering all companies requiring full value chain traceability with public supplier disclosure. They argue companies must identify suppliers beyond first-tier relationships and that stakeholders should have formal complaint mechanisms to trigger investigations.

This would increase pressure on fashion brands to improve supply chain oversight and worker protections.

Companies lose flexibility to maintain opaque supply chains and avoid disclosure of sourcing practices.

Confcommercio Urges Importer Protections in Forced Labor Ban

CONFCOMMERCIO - IMPRESE PER L'ITALIA, 17 Nov 2022

The association requests narrowing the supply chain definition to exclude external buyers and suppliers. They also demand financial protections for importers and greater involvement of business organizations in risk analysis.

This would minimize the financial liability and compliance burden for Italian importing companies.

Human rights groups and victims lose when fewer companies are held accountable.

Consultation response

Platform for International Cooperation on Undocumented Migrants, 29 Nov 2022

Migrant workers are at particular risk of violations of workers rights and forced labour across the world. In the European Union, undocumented migrant workers and those with precarious migration status make up a significant proportion of the workforce in several sectors, including those…

Consultation response

Platform for International Cooperation on Undocumented Migrants, 20 Jun 2022

Migrant workers in the EU are at particular risk of labour rights violations and forced labour. People with dependent or irregular status face particular risks of labour rights violations, that may amount to or turn into forced labour, through a combination of factors such as wage theft, excessive…

Textile industry urges predictable rules for forced labour bans

EUROPEAN APPAREL AND TEXTILE CONFEDERATION, 17 Jun 2022

EURATEX requests regulatory predictability and thorough impact assessments involving industry stakeholders. They highlight that companies lack full knowledge of every step in the chain.

This approach limits industry liability by shifting monitoring burdens toward public enforcement authorities.

Member State authorities will face higher costs to enforce complex supply chain rules.

Austrian Trade Union Federation Urges Stronger Forced Labor Ban

Österreichischer Gewerkschaftsbund, 29 Nov 2022

The federation calls for expanding the ban to include services, transport, and child labor. Companies must prove products are clean rather than authorities having to provide evidence. The law should mandate victim compensation and financial penalties for non-compliant importers.

Strengthening global labor standards helps the federation achieve its goal of reducing economic inequality.

Importing companies lose the ability to exploit regulatory loopholes and shift compliance costs to authorities.

European Branded Clothing Alliance urges phased-in forced labor ban

European Branded Clothing Association, 20 Jun 2022

EBCA requests a phased-in implementation and a risk-based approach to sustainable sourcing. They suggest certifying best efforts instead of requiring proof that no forced labour exists.

This approach would shield companies from immediate penalties and reduce compliance costs.

Human rights groups face higher evidentiary hurdles when reporting suspected forced labour violations.

FESI warns against replicating flawed U.S. labor bans

Federation of the European Sporting Goods Industry, 20 Jun 2022

FESI recommends that the Commission acknowledge industry-led initiatives. They urge the EU to avoid replicating the flawed U.S. import ban system. Companies should have a right to be heard before product withdrawal.

This prevents companies from being overburdened while protecting legitimate global business operations.

IKEA urges EU to prioritize due diligence over trade bans

Inter Ikea Systems BV, 20 Jun 2022

IKEA requests that legislation focuses on strengthening due diligence mechanisms rather than trade-based import bans. They also propose an implementation phase allowing for self-declarations and recognized third-party certifications.

IKEA would reduce complexity and logistical challenges by avoiding regional bans and harmonizing requirements.

Vulnerable workers lose economic support if companies divest from high-risk areas to avoid penalties.

Consultation response

Statkraft AS, 30 Nov 2022

Please find Statkraft's consultation response attached.

Swedish Trade Union Confederation urges total forced labor ban

The Swedish Trade Union Confederation, 20 Jun 2022

The organization calls for a horizontal ban on all products, including those transported with forced labor. There should be no exemptions for small businesses or any supply chain tiers. Authorities should detain suspect goods until importers prove the absence of forced labor.

This empowers unions by structurally involving them in the initiative's enforcement and implementation.

Importers and companies face significant fines and seizure of goods for labor violations.

Assonime seeks reward mechanism for forced labour due diligence

Associazione fra le società italiane per azioni, 29 Nov 2022

Assonime requests the Commission provide guidelines and risk databases before implementation. They propose a reward mechanism for reliable companies that proactively address forced labour.

Companies would receive legal certainty and avoid economic damage from supply delays.

European companies lose competitiveness against international rivals if controls are excessively burdensome.

Beet growers urge EU to ban forced labor sugar imports

International Confederation of European Beet Growers, 20 Jun 2022

The sugar industry wants the ban to cover modern slavery and child labor across the entire supply chain. They also call for mandatory agricultural labor inspections to be included in all EU trade agreements.

This would protect European farmers from being undercut by cheaper imports produced under poor labor conditions.

Major sugar exporters with documented labor violations would face restricted access to European markets.

ESIA urges longer deadlines and recycling in forced labour ban

European Electronic Component Manufacturers' Association, 30 Nov 2022

ESIA requests doubling the information request timeframe to 30 working days. They suggest recycling specific components instead of disposing of entire products. The regulation should also recognize existing industry due diligence schemes.

Focusing disposal on specific components reduces costs and prevents unnecessary waste.

Forced labour victims could see delayed enforcement due to extended investigation timelines.

amfori Urges Improvements to Proposed EU Forced Labour Ban

amfori - Trade with Purpose, 30 Nov 2022

amfori requests including state-imposed forced labour explicitly and allowing investigations into specific factories or regions. They also propose doubling the time for companies to respond to investigations to thirty days.

Businesses would avoid unfair prejudice by having more time to prepare high-quality evidence.

Factories and regions using forced labour would face broader and more effective bans.

Policy Hub Urges Harmonised Rules for EU Forced Labour Ban

Policy Hub - Circularity for Apparel and Footwear, 30 Nov 2022

The group requests harmonised implementation across member states to ensure legal certainty. They call for clearer evidentiary thresholds and longer response deadlines for investigations. They also advocate for the recognition of industry-led initiatives and standards.

Standardised procedures would protect legitimate trade from inconsistent or overzealous customs actions.

National authorities would lose the discretion to target specific industries or sectors.

World Benchmarking Alliance supports EU ban on forced labor products

Stichting World Benchmarking Alliance Foundation, 20 Jun 2022

WBA supports the EU initiative and recommends using its benchmarking data to assess corporate human rights performance. They emphasize that the ban should align with the Corporate Sustainability Due Diligence Directive to ensure comprehensive risk mitigation.

The alliance would gain greater influence as their benchmarks become essential for regulatory compliance.

Underperforming companies in the ICT and automotive sectors would lose access to the EU market.

Policy Hub warns against product-level forced labour ban

Policy Hub - Circularity for Apparel and Footwear, 20 Jun 2022

The group suggests regulating entire companies rather than individual products to ensure feasibility. They request a risk-based approach and significant time to adjust complex global supply chains.

Extended timelines and entity-level regulation would significantly lower the group's immediate compliance costs.

Forced labour victims face delayed protections if trade bans are used only as last resorts.

amfori urges pragmatic alignment in EU forced labour ban

amfori - Trade with Purpose, 20 Jun 2022

amfori asks for alignment with international standards and consistency with the Corporate Sustainability Due Diligence Directive. They advocate for an actionable tool that encourages continuous improvement rather than penalizing businesses that discover issues through due diligence.

Harmonized requirements would create a level playing field and reduce complexity for international traders.

Suppliers in countries with weak enforcement may lose market access without significant capacity support.

Japan Business Council Urges Legal Certainty for Forced Labour Rules

Japan Business Council in Europe, 30 Nov 2022

JBCE requests high legal certainty and earlier guidelines to properly comply with all requirements. They propose increasing investigation response times to thirty days to reflect supply chain complexity.

This would lower compliance costs and prevent the immediate loss of complex products.

Forced labour victims lose immediate protections if market withdrawal actions are delayed.

Austrian Labour Chamber urges broader ban on exploitative products

Bundesarbeitskammer Österreich, 20 Jun 2022

The Chamber advocates for extending the ban to all human rights violations. Customs should block imports from specific regions or companies based on suspicion. Restrictions must remain until workers receive compensation and conditions improve.

This empowers their members by integrating trade unions into formal monitoring roles.

Non-compliant firms and regions face public blacklisting and strict import bans.

German chemical industry warns against bureaucratic forced labour rules

Bundesarbeitgeberverband Chemie e.V., 20 Jun 2022

Legislation 'must not lead to counterproductive duplications' with existing sustainability rules. They call for a 'simplification of the individual due diligence' and reporting requirements. They argue it is 'not understandable' why the regulation covers products from the EU.

Avoiding these rules prevents companies from being 'overloaded by bureaucracy' and reduces costs.

Terre des Hommes urges child-centered reforms for forced labor ban

Terre des Hommes International Federation, 30 Nov 2022

The organization requests a child-centered approach including transition periods and supportive measures. They demand child participation and guaranteed access to legal remedies for all affected workers.

This would ensure the organization's child-protection priorities are legally integrated into EU trade enforcement.

Impoverished families lose their livelihoods while children face more dangerous, hidden forms of exploitation.

IHK Nord urges clearer rules on forced labor ban

IHK Nord e.V. - Arbeitsgemeinschaft norddeutscher Industrie- und Handelskammern, 29 Nov 2022

The organization calls for a narrower definition of forced labor products and clearer identification requirements for customs. They demand that authorities bear the burden of proof and request exemptions for critical goods.

Harmonized rules and early guidelines would reduce administrative costs and legal risks for companies.

Victims of forced labor lose protections if critical products receive exemptions from the ban.

TÜV Association urges using independent auditors to enforce forced labour bans

TÜV-Verband e. V., 30 Nov 2022

The association proposes that independent assessment bodies support national authorities with on-site inspections and investigations. They suggest using international standards to verify human rights declarations and save administrative resources.

This would create new business opportunities for TÜV companies to provide formal verification services.

Consultation response

Tony's Chocolonely, 20 Jun 2022

Tony’s Chocolonely is an impact company that makes chocolate and fights for equality in the chocolate industry. We exist to make 100% slave free the norm in chocolate. Not just our own, but all chocolate worldwide. Because the system is broken and it’s up to chocolate companies to fix it. We’ve…

Consultation response

First Solar GmbH, 30 Nov 2022

First Solar welcomes the European Commissions draft regulation. From raw material sourcing and manufacturing through end-of-life panel recycling, our commitment to Responsible Solar is underpinned by the belief that solar should never come at the price of people or the planet. What was once a…

German Confectionery Industry Supports Forced Labor Ban with Conditions

Bundesverband der Deutschen Süßwarenindustrie, 17 Jun 2022

The BDSI backs the ban but demands consistency with due diligence rules. They oppose shifting the burden of proof to companies.

The association would secure legal certainty and avoid significant investigative costs for companies.

Producers in developing nations lose out if strict rules cause companies to withdraw.

Consultation response

European Cocoa Association, 30 Nov 2022

The European Cocoa Association would like to thank the European Commission for being able to provide its feedback on the proposed Regulation on prohibiting products made with forced labour on the Union market, and would like to refer to the European Cocoa Association position paper that is attached.

Finnwatch urges EU ban on products made with forced labour

Finnwatch ry, 20 Jun 2022

Finnwatch supports a ban as a necessary supplement to due diligence rules, specifically targeting state-imposed forced labour. They demand transparency through public customs data and a registry of sanctioned entities. The ban should require companies to remedy harm before a ban is lifted.

Enhanced supply chain transparency would allow the NGO to monitor corporate conduct and report violations effectively.

Businesses relying on exploitative labour or state-imposed systems would face market exclusion and sanctions.

GLEIF urges EU to mandate global identifiers for supply chains

Global Legal Entity Identifier Foundation, 19 Jun 2022

GLEIF recommends mandating the Legal Entity Identifier to standardize due diligence and transparency across Member States. They suggest requiring companies to use standardized data templates to report and monitor their global suppliers.

Mandating this identifier would cement GLEIF's system as the universal standard for supply chain transparency.

Opaque businesses and subcontractors lose their ability to hide within complex supply chains.

Consultation response

Global Reporting Initiative, 30 Nov 2022

GRI welcomes this important initiative by the EU Commission, and is grateful for the opportunity to share our feedback in the attached response.

Consultation response

China Chamber of Commerce to the EU, 30 Nov 2022

The China Chamber of Commerce to the EU (CCCEU) is a business organisation that gathers Chinese-invested corporations in Europe. As such, the CCCEU speaks on behalf of about 1,000 Chinese enterprises in the EU. Its mission is to promote China-EU economic cooperation, to increase the mutual…

Consultation response

European Network of National Human Rights Institutions, 30 Nov 2022

Please, find our feedback attached.

Consultation response

Global Reporting Initiative, 20 Jun 2022

GRI (Global Reporting Initiative) would like to thank the European Commission for the opportunity to provide feedback to this initiative,and would like to reiterate our commitment to the European process and initiatives. As providers of the world's most widely used Sustainability Reporting…

SPECTARIS Urges EU to Ease SME Compliance on Forced Labour

SPECTARIS Deutscher Industrieverband für Optik, Photonik, Analysen- und Medizintechnik e.V., 19 Jun 2022

The association requests a central registry of blocked entities to simplify risk management. They also advocate for desktop reviews and clear customs documentation requirements for importers.

A central registry would lower audit costs and reduce administrative 'paper war' for small businesses.

Forced labour victims may remain unprotected if companies rely on easily faked desktop reviews.

Green REV Institute calls for forced labor ban in meat industry

Green REV Institute, 23 Sept 2022

The organization wants strict EU laws banning food made using forced labor. They demand new tools to monitor human rights in animal supply chains.

Strict regulations would help the organization promote a shift toward plant-based diets.

Global meat producers would face higher costs to monitor their complex supply chains.

Consultation response

International La Strada Association, 20 Jun 2022

La Strada International, European NGO Platform against Trafficking in Human Beings, comprising 25 member NGOs and 5 associate members in 24 European countries, welcomes the call for a Europe-wide, far-reaching ban on forced labour in the supply chain and the promise of a legislative draft to be put…

Consultation response

FRUCOM - European Federation of the Trade in Dried Fruit, Edible Nuts, Processed Fruit & Vegetables, Processed Fishery Products, Spices and Honey, 20 Jun 2022

FRUCOM represents European Union importers, and growers, processors, and traders, of edible nuts, dried and processed fruit and vegetables, and processed fish and seafood. Many of these products are either not produced in the EU or the production volume is not sufficient to meet the market demand,…