Forced labour is no longer only a labour rights or corporate responsibility issue. It is increasingly becoming a market-access and supply-chain concern. The EU Forced Labour Regulation (EUFLR) and the United States forced labour import regime both establish mechanisms capable of preventing products linked to forced labour from reaching their intended markets.
BHRTR’s new information note, “Forced Labour and Market Access,” examines how these two regimes operate, where they differ and what they mean for supply chains in Türkiye.
The EUFLR prohibits products made wholly or partly with forced labour from being placed or made available on the EU market or exported from the EU. Applying from 14 December 2027, the Regulation contains no general SME exemption or company-size threshold. Smaller Turkish suppliers exporting directly to the EU may therefore fall within its scope alongside multinational companies.
In the United States, Section 307 of the Tariff Act prohibits imports made wholly or in part with forced labour, while the UFLPA introduces a stronger evidentiary burden for goods linked to Xinjiang or listed entities. Importantly for Türkiye, final manufacture in Türkiye does not necessarily eliminate a forced-labour risk originating further upstream.
A central message across both regimes is the need to look beyond tier-one suppliers. Audits and certifications remain useful, but may not be sufficient on their own. Companies increasingly need deeper supply-chain visibility supported by bills of materials, certificates of origin, chain-of-custody records and effective verification.
Given Türkiye’s close commercial links with both the EU and the United States, these developments are particularly relevant for exporters and their suppliers.
BHRTR’s information note provides a comparative overview of the two regimes and highlights the key risks and practical steps businesses should consider.
