Feedback to the call for evidence for the initiative "Effectively Banning Products Produced, Extracted or Harvested with Forced Labour"

While DIHR welcomes the European Commission’s strong stance on the eradication of forced labour, when designing an initiative to address this pressing issue, the utmost care must be taken to ensure that any such measure places the needs of rightsholders at the centre and is coherent with other parallel regulatory developments such as the proposed Corporate Sustainability Due Diligence Directive.

The response notes that any initiative placing a ban on the import of goods produced using forced labour should not only seek to exclude goods produced using forced labour from the EU market, but also address the underlying issue of forced labour by placing affected rightsholders at the centre. The Initiative should not inadvertently exacerbate the adverse impacts on rightsholders by triggering immediate disengagement at the expense of encouraging companies to use leverage to ameliorate the situation of those working in conditions which amount to forced labour. Further, it is crucial that the Initiative includes provision for remedy and remediation for those in a situation of forced labour.