JBCE Position Paper Regarding the Guidelines on the Implementation of the EU Forced Labour Regulation

On 6 March 2026, JBCE submitted its answer to the call for evidence on the guidelines supporting the implementation of the EU Forced Labour Regulation.

JBCE’s position focuses on predictable, risk based, and coherent implementation that:

• Provides clear guidance for economic operators, competent authorities, and other stakeholders that are consistent with existing international standards (i.e. ILO indicators, the UNGPs and OECD).
• Takes into account the resources required for preparatory work and investigations, which depend on the size of the economic operator and its level of involvement in the risk of forced labour; provides training and capacity building support.
• Ensures transparent standards of evidence, access to the risk database and the EU's single portal, and consistent implementation across Member States.
• Prioritises remedial measures over indiscriminate disengagement.
• Ensures consistency with existing Industry standards, EU legislative requirements and evidence for proving sufficient due diligence implementation of human rights, including forced labour. (i.e. EUDR’s Due diligence statement, CSDDD, CSRD disclosures etc.).
• Fosters EU–Japan cooperation on capacity building and data sharing to address upstream risks.

For more information, please contact info@jbce.org