Better Trade Collective Submits Recommendations on EU Forced Labour Regulation Implementation
Better Trade Collective has submitted recommendations to the European Commission in response to its call for evidence on the development of guidelines for implementing the EU Forced Labour Regulation (FLR).
The forthcoming guidelines will play an important role in shaping how authorities, companies, and stakeholders identify and address forced labor risks in global supply chains. Effective implementation will depend on clear evidentiary standards, practical documentation expectations, and meaningful engagement with workers and civil society.
Our submission draws on our experience developing and administering the U.S. Department of Labor’s List of Goods Produced by Child Labor or Forced Labor, including the procedures used to evaluate multi-source evidence and publish transparent determinations.
Based on that experience, our recommendations emphasize several key principles for effective enforcement:
- Clear evidentiary standards that allow authorities to evaluate information from multiple sources, including worker testimony and civil society reporting
- Structured documentation frameworks that help companies understand what information may be relevant during preliminary inquiries
- Worker-centered due diligence, including the use of grievance mechanisms and worker-voice systems as sources of credible information
- Practical remediation guidance focused on restoring affected workers and preventing recurrence
- Consistent administrative procedures that improve transparency, predictability, and efficiency for authorities, companies, and stakeholders alike
We also highlight the important role that civil society organizations play as trusted intermediaries, particularly in contexts where workers face barriers to reporting exploitation directly.
As governments increasingly adopt forced labor import bans and due diligence frameworks, administrative procedures for evaluating evidence and conducting investigations will become a central component of effective enforcement.
We appreciate the Commission’s consultative approach and look forward to continued engagement as the guidelines are developed.
📄 Read our full submission here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/16292-Guidelines-on-the-implementation-of-the-EU-rules-on-forced-labour/F33378071_en
