World June 3, 2026 10:39 AM

How the U.S., EU and U.K. Differ in Tackling Goods Linked to Forced Labour

A comparative look at enforcement tools, corporate duties and timelines shaping trade and compliance

By Nina Shah

Governments in the United States, Europe and Britain have established differing legal approaches to prevent goods produced with forced labour from entering their markets. The U.S. relies on long-standing customs prohibitions and a targeted law addressing forced labour in China's Xinjiang region. The EU is introducing a comprehensive product ban with a 2027 start date. Britain and several European countries favour transparency and corporate due-diligence regimes rather than customs import bans. The patchwork of measures creates distinct compliance obligations for companies and varying enforcement mechanisms at borders and through corporate oversight.

How the U.S., EU and U.K. Differ in Tackling Goods Linked to Forced Labour

Key Points

  • U.S. enforcement combines a long-standing customs prohibition under the Tariff Act of 1930 with the targeted Uyghur Forced Labor Prevention Act, giving customs authorities powers to detain, exclude or seize suspected goods.
  • The EU will implement a comprehensive ban on products made with forced labour across the single market from 14 December, 2027, covering both imports and domestically produced items.
  • The U.K., Germany, France, the Netherlands, Finland and Norway rely mainly on transparency and corporate due-diligence laws; these regimes impose reporting and vigilance obligations rather than direct customs import bans, affecting corporate compliance and procurement practices.

June 3 - The United States has proposed new tariffs on imports from 60 economies after accusing trading partners of failing to keep goods made with forced labour out of their markets. That action highlights contrasts in how Washington, European capitals and London regulate products linked to forced labour, with different tools aimed at border controls, corporate transparency and supply chain due diligence.


United States

At the centre of U.S. enforcement is section 307 of the Tariff Act of 1930, which bars the importation of any good produced wholly or in part by forced labour, convict labour or indentured child labour. The statute equips U.S. Customs and Border Protection with a customs enforcement mechanism that permits the detention, exclusion or seizure of goods believed to be tied to forced labour.

Complementing that long-standing prohibition is the Uyghur Forced Labor Prevention Act, which took effect in June 2022. The UFLPA is focused on preventing goods made with state-sponsored forced labour of Uyghurs and other ethnic minorities in China’s Xinjiang Uyghur autonomous region from entering the U.S. market.


United Kingdom

The United Kingdom addresses human trafficking and forced labour mainly through the Modern Slavery Act 2015. That law consolidates prior offences and strengthens penalties, while also obliging companies to publish reports outlining steps taken to tackle slavery and human trafficking within their operations and supply chains. The law functions primarily as a transparency regime rather than as an import ban enforced at the border.


European Union

The European Union has adopted a Forced Labour Regulation that introduces a ban on products made with forced labour, ensuring such products cannot be sold in the EU market. The prohibition is broad in scope, applying to all products whether they are imported into the EU or produced within it for domestic consumption or for export. The rules are scheduled to take effect on 14 December, 2027.


Germany

Germany operates a corporate due-diligence approach through its Supply Chain Due Diligence Act. The law requires large companies to address human-rights and certain environmental risks in their supply chains, including the risk of forced labour. It applies to companies in Germany with at least 1,000 employees. For serious violations, affected companies can face fines and may be excluded from public contracts. The German regime focuses on corporate responsibilities rather than on customs-based import prohibitions.


France

France’s duty of vigilance law requires large firms to design and implement vigilance plans identifying risks and preventing serious harm to human rights, fundamental freedoms, health, safety and the environment. The law’s coverage extends to the company’s own activities, entities it controls, and subcontractors and suppliers with which it has an established commercial relationship. Like Germany’s law, France’s measure emphasises corporate obligations rather than halting goods at the border.


Netherlands

The Netherlands has been progressing child-labour due-diligence legislation, but official guidance indicates the effective date is not yet final. That Dutch initiative is not framed as a general forced-labour import ban. Dutch companies will also become subject to the EU’s forced-labour product ban once it starts applying in December 2027.


Finland

Finland is preparing national legislation to implement the EU’s forced-labour product ban when it takes effect from December 2027. A draft law would designate the Finnish Supervisory Agency as the national authority responsible for investigations, decisions and sanctions in Finland. The government intends to submit the proposal to parliament in autumn 2026.


Norway

Norway’s Transparency Act, in force since 2022, targets human-rights abuses and indecent working conditions associated with the production of goods and services both domestically and in global supply chains. The law mandates that larger companies conduct due diligence and grants the public a right to request information. As with several European statutes, Norway’s law is oriented towards transparency and due diligence rather than customs-based import restrictions.


The resulting legal landscape is therefore a mix of customs enforcement mechanisms, product bans and corporate duty frameworks. Some jurisdictions rely on border controls to prevent the physical entry or sale of goods linked to forced labour, while others place the primary burden on companies to identify and mitigate risks within their supply chains.

Risks

  • Timing and implementation uncertainty: several measures are not yet in force or have future effective dates (for example, the EU ban starts 14 December, 2027; the Netherlands law has no final effective date; Finland plans to submit its draft in autumn 2026), creating transitional compliance uncertainty for companies and markets.
  • Regulatory divergence: differing enforcement mechanisms - customs seizures versus corporate due-diligence regimes - may complicate compliance for multinational companies and affect sectors with complex global supply chains such as manufacturing, retail and logistics.
  • Sanctions and procurement consequences: corporate-focused laws (Germany, France) can carry fines and exclusion from public contracts for serious violations, posing financial and revenue risks for large firms contracting with government bodies.

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