Deforestation and forced labour rules

Two rules reach a brand through its suppliers rather than through its products or its parcels. One concerns where a raw material was grown, the other who made the goods. The dates below are as reported. In both cases the answer has to come from a supplier before it can come from you.

The deforestation statement

The EU deforestation regulation, EUDR, applies from 30 December 2026 to large and medium operators, as reported. It covers seven commodities (cattle, cocoa, coffee, palm oil, soya, wood and rubber) and products derived from them. For goods in scope, the company placing them on the EU market has to submit a due diligence statement beforehand and ensure the goods were produced legally. The level of checks depends on the risk level assigned to the country of production: low, standard or high.

The practical consequence is a question to each supplier of an in-scope material: where was it produced, and can you show it was produced legally. That is why our supplier record asks an in-scope supplier where the goods were produced, down to the site's coordinates; a supplier that cannot say leaves a gap in your statement.

The forced labour ban

Regulation (EU) 2024/3015 applies from 14 December 2027, as reported. It bans products made with forced labour from entering, circulating in or leaving the EU market. The burden of proof sits with the authorities, who investigate; a product found non-compliant faces withdrawal and disposal. The Commission published guidelines in July 2026, which are non-binding, as reported. As reported, there is no statement to file in advance; you may instead have to answer an investigation. For that, you would want a record of who made the goods and the checks you ran.

One rule asks where the material grew, the other who made the goods, and the supplier record answers both.

The supplier record

For the deforestation rule: which of the seven commodities the supplier deals in, and where the goods were produced; our record takes the site's coordinates. For the forced labour rule, we hold the supplier's identity, the code of conduct they signed and when, the certifications they hold with the documents behind them, and whatever screening you ran. The rule does not list these; they are the evidence you would want to show an investigator. The supplier directory in your account has a field for each of these, and Suppliers and purchase orders walks through them: the commodity ticks, the factory latitude and longitude, the code-of-conduct date, the certificates with their evidence links. The screening status and the due diligence score are set on our side, so that an auditor can rely on them.

Supplier record and passport

The passport is expected to hold material composition; these rules ask for the proof of where and how the material was produced. A passport names a material and a country. The supplier record behind it, with the producer, the place and your checks, answers a question under either rule. Passport data from suppliers describes the collection sheet that names who provides each field, and the supplier fields we use for these two rules are on it.

Steps before the dates

Sort your suppliers by commodity: anyone supplying cattle, cocoa, coffee, palm oil, soya, wood or rubber, or products derived from them, is in scope of the first rule, as reported. Ask each where the goods were produced and record it; our record takes the coordinates. For every supplier, get the code of conduct signed and dated and the certificates linked to their documents. Then look at the evidence you could show an investigator in a week: if it is a folder of emails, move it into the supplier record now.