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What the EU rule actually changes
From 14 December 2027, the EU Forced Labour Regulation will prohibit products made with forced labour from being placed or made available on the EU market, or exported from it. It covers products regardless of origin. The European Commission's explanation also makes a distinction that matters when buyers contact suppliers: the regulation itself does not introduce a standard audit or reporting obligation. Businesses must address the product risk, but the regulation does not prescribe one document pack for every order.
The Commission launched its preparedness portal on 30 June 2026. Authorities will use a risk-based process and may request information from businesses if concerns arise. The portal is a reason to prepare a usable answer now; it is not evidence that a particular footwear supplier or sourcing region has a problem.
The buyer implication: know what an answer covers
A supplier might share a company policy, a factory audit or a statement about its material sourcing. Each may be useful, but each answers a different question. A policy describes an approach; an audit concerns a stated site and period; a material statement needs a clear connection to the footwear being proposed. None should silently become a verdict on every product the supplier could make.
For an early sourcing decision, the practical question is narrower than “Can you prove this shoe is compliant?” Ask what the supplier can confirm for the proposed product, what supports that answer, and what remains provisional. A clear unknown is more useful than a confident statement whose scope nobody can explain.
A useful first request: “For this proposed footwear style, please identify the production and principal material information you can currently confirm, the documents or records those answers relate to, and any points that still need checking. Who would handle the follow-up?”
This is a buyer communication example, not a prescribed EU questionnaire. A smaller project may start with a short exchange; a material risk may justify more targeted evidence or specialist review. The Commission's voluntary guidance describes due diligence as risk-based and proportionate, and says the guidance creates no new obligation.
Before the order: close the decision, not the file
Read each reply against the decision you are about to make. Does it describe the product under discussion, or only the supplier in general? Is the supporting document identifiable by scope and date? If an important point is still open, who can clarify it and when? Keep the answer and its limits with the current sourcing brief so that a later decision does not rely on an earlier, broader claim.
This approach also leaves room for a supplier to give a qualified answer. A useful reply may say that a source is proposed but not yet fixed, or that a document applies to one site rather than every facility. That is information to resolve according to its importance; it is not, by itself, evidence of forced labour.
Supplier information is only part of the buyer's view. The Commission's guidance also points to companies' own purchasing practices and order timelines as possible factors in addressing forced-labour risk. A buyer should therefore avoid treating a supplier form as a substitute for reviewing its own decisions where those decisions could affect the risk.
What this check cannot establish
An answerable set of questions can improve a sourcing decision. It cannot certify that a product is free from forced labour, and the regulation does not turn a particular certificate into a safe harbour. If credible, significant concerns cannot be assessed through the available information, the next step is a focused risk review and appropriate professional advice, not a blanket approval or a country-level assumption.
For the general supplier assessment and initial request, continue with How to Evaluate a Shoe Manufacturer and How to Write a Footwear RFQ.
