SUMMARY

On 8 December, FESI took part in the first Commission's Informal Expert Group meeting to discuss and advise the Commission on the development of the guidelines and implementation of the EU Forced Labour Regulation (slides and speaking points attached). The group is composed of around 35 members from industry, civil society, unions, international organisations and academia (full list attached). The next meeting will take place in early February.

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MORE DETAILS

Outcome of first meeting

Rules of Procedure Adopted

• Consensus-based decision-making, with simple majority voting only as a last resort. Chatham House rules apply.
• Possibility to create formal or informal subgroups and invite external experts.
• Strong preference for in-person meetings due to confidentiality.
• Expected 3–4 meetings per year (official minimum: two).

Transparency & Documents

• Documents published on the Commission’s transparency page may be freely shared.
• More sensitive documents will be shared case-by-case, depending on topic.
• Standard 30-day circulation deadline may be shortened to 5 days; a 14-day target was suggested for preparatory materials.

Coordination with Member States

• A “Union Network on Forced Labour” will coordinate competent authorities.
• Meetings may take place back-to-back with the Expert Group, and members may occasionally be invited to brief Member States.

2. Key discussion topics

Implementation Needs

Members emphasised the need for:

• Clear, practical and regularly updated guidelines for both authorities and companies.
• A transparent and predictable investigation process, including clarity on:
  • triggers for investigations
  • what constitutes “independent and verifiable information”
  • expectations for evidence and documentation

Harmonised practices across Member States to avoid fragmentation.

FESI’s key speaking points (attached)

• Strong support for the Regulation’s objectives.
• Need for a risk database, regularly updated and paired with a notification system.
• Need for standardised documentation templates and clarity during investigations.
• Importance of addressing the interplay with CSDDD, especially if access to value-chain information becomes restricted.

Indicators of Forced Labour

Discussion focused on the use of:

• ILO indicators as a baseline
• Differentiation between sectoral, product-level, geographical, and state-imposed risks
• Realistic expectations for SMEs

NEXT STEPS

The next meeting will likely take place in the week of 7 February 2026. Once we receive the agenda we will share it with members to collect feedback for the in person discussions. In early 2026, the Commission is also expected to open public consultations for the guidelines.

‍Both the guidelines and risk database will be published in June 2026.

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