Suspected Forced Labor 2027 – Supplier Letter, Evidence & Authority | Word/PDF/Excel

What do you do when a supplier, product component, or factory is singled out in an allegation of forced labour? This niche document package helps importers, manufacturers, wholesalers, e-commerce businesses, and exporters document a specific suspicion, request supplier evidence, trace affected product batches, and respond to a potential request from the authorities – without confusing an allegation with an established ban.

The EU's Regulation (EU) 2024/3015 on products made with forced labour will start to apply on 14 December 2027. The regulation prohibits products made with forced labour from being placed on or supplied on the EU market or exported from the EU. It also covers relevant distance and online offers aimed at the EU. However, it does not introduce any new general obligation for all companies to conduct annual audits, report, or establish a specific standardised due diligence register. Other laws may still contain specific obligations.

Delivery for SEK 79: five operational work templates in Swedish, a Swedish user guide and a separate English User Guide, all in both editable Word (DOCX) and searchable, printable A4 PDF. An Excel register (XLSX) with nine tabs and 612 formulas is included. Total 7 DOCX + 7 PDF + 1 XLSX = 15 customer files in ZIP. The PDF copies contain no interactive form fields.

Who needs the package?

Importers, manufacturers, retailers, e-commerce businesses, wholesalers and exporters who receive a specific risk warning about forced labour in manufacturing, harvesting, extraction or a sub-supplied component. Relevant functions are purchasing, quality, sustainability/ESG, compliance, legal and supply chain management. The package is intended both for preparations ahead of 2027 and documentation of actual cases when the rules apply.

Complete file list

Excel with nine worksheets and 612 formulas

The worksheets are named Read me, Overview, Cases, Product Batches, Suppliers, Evidence, Authority Letters, Actions and Sources. The overview shows registered cases, traceability gaps, unanswered supplier questions, incomplete evidence, authority letters and open actions.

Administrative statuses include “COMPLETE CASE”, “ASSESS APPLICABILITY”, “VERIFY BATCH”, “AWAITING SUPPLIER RESPONSE”, “REVIEW COUNTER-EVIDENCE”, “CLARIFY AUTHORITY PHASE”, “CALCULATE DEADLINE MANUALLY”, “VERIFY AUTHORITY ACKNOWLEDGEMENT” and “REVIEW CLOSURE”. Excel never provides legal approval, an authority decision or a guilt classification. 26 out of 26 scenario tests passed. The customer's workbook starts with zero cases and contains no test data.

How to use the templates – seven steps

1. Delimit the allegation. Identify the actual product, manufacturing step, factory/supplier and affected batch. Separate the source of the allegation from verified fact.
2. Check the legal situation. The Article 3 ban applies from 14 December 2027. Articles 1 and 4 govern scope and certain distance sales. A risk warning does not automatically mean the ban is violated.
3. Protect affected persons. Handle information about workers and whistleblowers carefully and securely. Do not enter the names of vulnerable persons in an unprotected spreadsheet.
4. Request relevant supplier information. Ask specific questions about the production stage, components, source evidence and any measures. State a reasonable voluntary/contractual response time without incorrectly referring to Article 17.
5. Evaluate the evidence. Document multiple perspectives, independent sources, contradictions and uncertainties. A signed certificate from the supplier is not automatically sufficient evidence.
6. Handle a potential formal request from the authorities. Article 17.2 normally states 30 working days from receipt for the operator's response to the request during the preliminary phase. For Article 18, the concrete formal investigation request and response time apply. Excel does not calculate the deadline automatically.
7. Decide and follow up. Distinguish voluntary precautionary measure, contractual decision and an actual authority regulation under Article 20/22. A final assessment is made separately by the competent person.

Legal control – nuances that make a difference

Regulation (EU) 2024/3015, Article 1.3: the regulation does not create new general due diligence obligations beyond those already resulting from other Union or national law. The European Commission clarifies that the regulation does not generally prescribe mandatory audits or annual reporting. Read the legal act and the Commission's guidance.

Articles 3 and 4: goods made with forced labour may not be placed on or supplied on the EU market or exported from the Union when the ban applies. Distance offers aimed at the EU market may be covered. The rules do not apply solely to products imported from third countries.

Article 17.2: when the competent authority requests information during the preliminary investigation, the economic operator shall respond within 30 working days from the day the request is received. This should not be used as a general response time for the company's voluntary letter to a supplier.

Articles 18, 20 and 22: a formal authority investigation follows a specific procedure. The authority establishes a potential violation. The compliance deadline of the decision under Article 22 has its own rules, including specific minimum periods; it should not be confused with the Article 17.2 authority question or an internal supplier deadline.

Article 1.2: the regulation does not regulate the withdrawal of products that have already reached end users within the EU. However, any other product safety and consumer rules must be assessed separately.

The Commission's guidance 2026/C 4637: describes practical risk work and possible voluntary measures but does not create new binding audit requirements. Read the official guidance.

Difference from Mallbutiken's existing products

The existing EU Forced Labour Regulation 2027 – Risk Assessment, DDQ & Supply Chain provides a general model for risk analysis and supplier review. The new specialist product is intended for a single concrete case: an allegation, traceable product batch, request for evidence and a possible authority question with a specific deadline.

Supplier Code & ESG Due Diligence is in turn a broader contractual and policy area. This product does not replace such basic work or other laws, but complements it with a delimited event process.

Frequently Asked Questions

Does the ban on forced labour apply from 2026?

No. The regulation already exists but the main ban starts to apply on 14 December 2027. Preparations can start earlier, but the product should not be marketed as if all material requirements already apply during 2026.

Must every e-commerce business conduct an annual forced labour audit?

Not according to this regulation. Article 1.3 introduces no extra general due diligence obligation, and the Commission expressly explains that the regulation does not introduce a universal audit or reporting requirement. Other laws or agreements may still apply.

Is it always a 30-day response time?

No. Article 17.2 applies 30 working days from receipt of a certain formal request from the competent authority during the preliminary phase. It does not automatically apply to a private supplier letter and does not mean 30 calendar days.

Is an allegation equivalent to the supplier having committed forced labour?

No. An allegation is an assertion or risk basis; the competent authority can investigate and decide according to the regulation's procedure.

Can we voluntarily pause a product during investigation?

The company may need to assess risk-based and contractual measures, but a voluntary sales pause should be documented as a separate business and risk decision – not as an authority regulation.

Must goods already with EU consumers be taken back?

Article 1.2 excludes the withdrawal of products that have already reached end users from this regulation. Other applicable requirements may entail other obligations.

Can Excel give a legal green light?

No. The spreadsheet calculates administrative items and marks follow-up needs. Evidence and a potential authority decision must be handled and assessed separately.

Are all main templates included in English?

No. Five work templates and Excel are in Swedish. An English User Guide for their use is included, but it is not a full translation of all forms.

Official Sources and Quality Status

Regulation (EU) 2024/3015; European Commission's explanation of the ban and process; Commission's guidelines 2026/C 4637.

Version 1.0, AI-assisted legal source control 9 November 2026. All 14 PDF pages have been reviewed for text and page boundaries, Excel contains 612 formulas and 26 out of 26 approved scenario tests, and the ZIP delivery contains 15 privacy-controlled files. No external lawyer, authority, labour law expert or independent auditor has approved the templates. The document package does not replace an authority decision, a real system for worker protection or a competent legal review.