Still figuring out what PPWR actually requires from your team? You’re not alone. Here are the three things QA, Sustainability, and Packaging teams in F&B should know:
EUFLR
December 2027
EU Forced Labour Regulation
The EUFLR applies to all products, from any sector or origin. From 14th December 2027, any product made in whole or in part with forced labour can't be placed on the EU market, sold or exported.
The EUFLR goes beyond tier 1, all actors in the supply chain are liable, there is no size threshold. However, transportation, warehousing and logistics services are exempt.
Your evidence has to exist before anyone asks for it. When an authority requests information, you get 30 working days to respond, and 30–60 working days if a formal investigation opens. That isn't enough time to build supply chain maps, chain-of-custody records and supplier data from scratch.
— EUFLR timeline
Supply chain evidence takes time to build. Don't wait until it's too late.
Your evidence needs to be in place well before the EUFLR applies. Mapping your supply chain, waiting for supplier responses and building a record can take months.
September 2026
Commission guidance was published on how the EUFLR will be implemented, how investigations are structured & evidence authorities may request.
17th November 2026
A specific session for the food industry run by the Commission. Where they discuss risks and procedures companies should be aware of in the run up to the EUFLR.
TBD- Before December 2027
The risk database will be released by the Commission to give companies direction in assessing forced labour risks.
14th December 2027
The EU Forced Labour Regulation applies.
September 2026
Commission guidance was published on how the EUFLR will be implemented, how investigations are structured & evidence authorities may request.
17th November 2026
A specific session for the food industry run by the Commission. Where they discuss risks and procedures companies should be aware of in the run up to the EUFLR.
TBD- Before December 2027
The risk database will be released by the Commission to give companies direction in assessing forced labour risks.
14th December 2027
The EU Forced Labour Regulation applies.
— Does the EUFLR apply to you?
Understand the regulation.
Know where you stand.
The EUFLR bans any product made with forced labour from being placed on the EU market. It covers every product and every company, with no size threshold. This regulation goes beyond tier 1, if the product is made using forced labour, no matter where in the supply chain, you are liable.
1. What counts as forced labour?
The EUFLR uses the International Labour Organization (ILO) definition: work taken from someone under threat of a penalty that they didn't offer voluntarily. It can be privately imposed, which covers most cases, state-imposed, or forced child labour.
Indicators of forced labour
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Violence, threats or intimidation
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Debt bondage or withheld wages
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Restricted movement or retained ID documents
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Deception, forced recruitment, or abusive working conditions
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Excessive overtime, isolation & abuse of vulnerability
2. HOW DOES A PRODUCT GET INVESTIGATED?
Authorities take a risk-based approach. They prioritise by the severity of the forced labour, the volume of product on the EU market, and the tainted part's share of the final product. From December 2027, NGOs, workers and competitors can also report cases through a central submission point.
What happens if an investigation is opened?
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Information request: the authority asks for supply chain information, including any due diligence you've done. You have about 30 working days to reply.
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The investigation opens only if there's a substantiated concern, and you have 30–60 working days to submit information.
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If you don't cooperate: the decision can be based on whatever other facts are available.
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Early resolution: strong evidence at the request stage can close a case before an investigation opens.
3. What happens if a product is banned?
The ban applies to the product itself, so every company selling it has to act, not only the one investigated. It applies from 14 December 2027, including to stock made or imported before that date.
What this means
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Withdraw the product and remove online listings within 10 working days for perishables, or 30 for other goods.
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Dispose of it at your own cost, by recycling or by donation for perishables.
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Fines are applied which differ by Member State. They only apply if you fail to comply with a ban.
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To lift a ban, you have to show the forced labour has been removed from the supply chain.
Due diligence isn't mandatory under the EUFLR. However, when an authority asks, your supply chain evidence is your only defence: maps of direct and sub-tier suppliers, chain-of-custody records, and documents linking the finished product to its raw-material source. Companies that can produce that evidence quickly can resolve concerns before an investigation opens.
Start from the data you already have
You don't need to build forced labour due diligence from scratch. Supplier certificates, records, social audits and specifications already show who you buy from, what you buy and where it comes from. With Simvia this data sits in one place, connected to a network of 200,000+ suppliers. The sooner you review what you hold, the sooner you'll see the gaps.
Step 1 · Start preparing now using your existing data
Map beyond tier 1
The ban applies to forced labour anywhere in the supply chain. Authorities can ask for maps of direct and sub-tier suppliers, ownership structures, and documents linking the finished product to its raw-material source.
Simvia maps supply chain relationships from source to shelf, with digital supplier traceability that shows producers, origins and products. Mapping sub-tiers takes time and depends on supplier responses, so start early.
Step 2 · Q4 2026 · Supply chain mapping
Find your forced labour hotspots
The Commission Guidelines advise companies to scope risk by geography, sector and product, and then prioritise by severity. Simvia's Sustainability Risk Assessment includes dedicated forced labour and child labour indicators based on ILO data. These sit alongside 10 social risk indicators and are weighted by your real sourcing volumes per product and origin. You can see where the risk is highest and explain why you've focused there.
Step 3 · Q4 2026 – Q1 2027 · Risk assessment
Build forced labour criteria into supplier approval
The Guidelines recommend in-depth assessments where risk is high and say due diligence should be proportionate to risk. Simvia lets you set requirements based on the risk of a product, a region, or a combination of the two. When forced labour or child labour risk is high, you can request more information from suppliers before an issue arises, and your effort goes where the risk is.
Step 4 · Q1 2027 · Supplier approval
Act on risks and keep the evidence
Authorities want to see what you've done, not just what you found. Simvia connects risk assessment and supply chain compliance in one platform. You can turn risk hotspots into supplier follow-ups and corrective actions, and collect evidence of mitigation over time, such as documents, certifications and operational improvements. Every month of tracked progress before December 2027 is evidence you'll have if an authority asks.
What does this mean in practice?
A risk assessment flags a high-risk origin for a key ingredient. The buyer sends the supplier a targeted follow-up, agrees a corrective action plan, and tracks progress every quarter until the risk is addressed.
Step 5 · 2027 · Mitigate & monitor
Be ready to prove it
A strong response to an information request can close a case before an investigation opens. If you don't cooperate, the decision can be based on whatever other facts are available. Simvia keeps your compliance information structured and ready to share, so you can produce clean, complete records the moment an authority asks. The window for building that evidence is now, not when the request arrives.
What does this mean in practice?
An authority asks a fresh produce importer about a product line. The team that has been collecting data since 2026 exports supplier lists, traceability records and audit evidence in an afternoon. The team that waited spends the 30 working days chasing suppliers.
From 14 Dec 2027 · Information requests
What should companies do now?
Data is your protection against a product ban.
Start building it now with Simvia.
When an authority asks about a product, your supply chain data is your only defence, and you'll have about 30 working days to produce it. Companies that start now can build that evidence base over time. Companies that wait until 2027 will be building under pressure.
3 steps to PPWR Compliance
1. Compliance evidence & technical file readiness:
Supplier documentation, data verification, and audit-ready file maintenance.
2. Packaging redesign
Material selection, design modification, and structural changes to meet customer and regulatory requirements.
3. Reporting & fees
Identify roles and responsibilities and calculate fees
Compliance evidence
For many companies, the largest workload PPWR requires is managing compliance evidence. PPWR requires managing data and evidence across many suppliers, packaging formats and SKUs.
PPWR introduces a shift in sustainability regulation with obligations distributed across quality, procurement, packaging & sustainability teams
Your EUFLR Compliance journey
Where to start now
Start with your data
Review the supplier, certificate and audit data you already hold. It's your baseline.
Begin mapping beyond tier 1
Trace product back as far as you can. Start supplier engagement early and include as many sub-tier 1 suppliers as possible.
Assess forced labour risks
Rank forced & child labour risk by product, region and country.
Set up risk-based requirements
Set up additional requirements for suppliers of high-risk products and regions before issues arise.
Keep evidence ready
Build a centralised database of your due diligence so you can respond quickly if an authority asks for information.
What is the EU Forced Labour Regulation (EUFLR)?
The EU Forced Labour Regulation (Regulation (EU) 2024/3015) bans products made with forced labour from being sold in the EU market or exported from it. It covers every product type and every stage of the supply chain, including harvesting, extraction, production and processing. Forced child labour is included.
When does the EU Forced Labour Regulation apply?
The EUFLR entered into force in December 2024 and applies from 14 December 2027. From that date, national authorities and the European Commission can investigate products suspected of involving forced labour. Companies should start mapping their supply chains and assessing risks now, so they're ready before enforcement begins.
Which companies does the EUFLR apply to?
The EUFLR applies to all companies that place products on the EU market or export from it. This includes businesses of every size and origin, with no turnover or employee thresholds. Authorities take a risk-based approach, considering a company's size, resources and the scale of the forced labour risk.
Does Simvia assess forced labour risk?
Yes. The Sustainability Risk Assessment includes forced labour and child labour indicators based on ILO data, scored by product, origin and sourcing volume.
Using Simvia you can set up requirements based on the risk of different products, regions and countries so companies can request additional information on a proactive basis from their suppliers if the forced or child labour risk is high for that product.
