Forced labour is publicly recognised as the most common form of modern slavery, and in many cases, it affects the most vulnerable and excluded groups in society. Currently, it is estimated that 16 million people are in forced labour in the private sector at any given time.

Due to the scale of this abuse, the result is that many companies active in the European Union provide products and services on the single market, which have forced labour in their value chains.

Civil society has long called for the EU to tackle this issue and ensure that companies acting in the EU are tackling and removing forced labour from their value chains.

Forms of import controls on products made or transported, in whole or in part, with forced labour already exist in other jurisdictions around the world, notably the United States. The European Parliament has consistently called for “import bans” for products made with forced labour into the EU.

In response, the European Commission is currently assessing how to introduce “effective action and enforcement mechanisms to ensure that forced labour does not find a place in the value chains of EU companies”. Consideration of import controls on forced labour products coincides with the forthcoming European Commission legislative proposal on Sustainable Corporate Governance.

In this paper, civil society organisations working in this field highlight some key considerations relevant to the development and functioning of these two parallel policy processes.