Submission to the European Commission on the EU Forced Labour Regulation
March 6, 2026
The Coalition to End Forced Labour in the Uyghur Region welcomes the opportunity to contribute to the European Commission’s development of Guidelines under Article 11 of the Forced Labour Regulation (FLR). This submission aims to contribute to the development of that guidance, particularly with respect to systemic state-sponsored forced labour.
Investigative approaches must also consider state policy, implementation capacity, and labour mobilisation programmes as enterprise-level indicators alone are insufficient in situations of state-imposed forced labour.
The risk-based framework should prioritise credible allegations of systemic forced labour, applying “facts available” when information is obstructed, recognising civil society evidence, and mapping supply chains beyond Tier 1 to trace exposure to labour transfer programmes.
In contexts where forced labour is embedded in state policy and remediation is not feasible, the Guidelines should set clear expectations for robust due diligence, responsible disengagement, and strengthened international coordination to prevent goods linked to forced labour from entering the EU market.
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