Introduction
In December 2025, Ireland introduced Statutory Instrument No. 623 of 2025 – the European Union (Prohibiting Products made with Forced Labour on the Union Market) (Designation of Competent Authorities) Regulations 2025 (the Regulations). The Regulations are concerned with the implementation and enforcement in Ireland of the EU-wide ban on products made with forced labour set out in Regulation (EU) 2024/3015.
Background
Regulation (EU) 2024/3015 (the Forced Labour Regulation) establishes an EU-wide ban on products made with forced labour, that is to say, 'all work or service which is exacted from any person under the threat of a penalty and for which the person has not offered himself or herself voluntarily.' The ban applies to all products, whether imported or produced within the EU for domestic consumption or export.
The Forced Labour Regulation will depend - when it enters into application on 14 December 2027 - for its effectiveness within the EU on each EU Member State, including Ireland, to put suitable enforcement mechanisms in place. The Regulations are Ireland’s response, identifying the relevant authorities that will carry out the relevant checks, investigations, and enforcement actions.
Irish Competent Authorities
The Regulations designate the Workplace Relations Commission (WRC) as Ireland’s “competent authority” for the purposes of enforcing the Forced Labour Regulation.
The WRC is an independent, statutory body which, aside from promoting the improvement and maintenance of workplace relations, is responsible for promoting and encouraging compliance with employment rights legislation. Its appointment as a competent authority under the Regulations reflects its expertise in labour standards, exploitation, and employment-law enforcement.
The WRC will be responsible under the Regulations for: (i) conducting or coordinating investigations into suspected forced labour; (ii) assessing evidence relating to labour conditions in supply chains; and (iii) making formal determinations as to whether forced labour exists and issuing binding decisions restricting access to products concerned or requiring their withdrawal from the market.
Under the Regulations, relevant market surveillance authorities in Ireland, such as the Competition & Consumer Protection Commission (CCPC), will also play a central role by providing product-level enforcement once a forced-labour determination is made by the WRC and by ensuring that prohibited products are (i) withdrawn or recalled; (ii) prevented from being placed or made available on the Irish market; and (iii) disposed of or rendered compliant where possible.
Forced Labour in Ireland
Regrettably, one does not have to look too far for examples of forced labour. Forced labour and exploitation remain persistent risks across a range of sectors in Ireland, particularly in industries such as hospitality, food services, agriculture, construction, and certain manufacturing sectors where irregular work patterns, migrant labour and complex supply chains can mask abusive practices. In the hospitality industry, for example, enforcement bodies have uncovered a number of cases of extreme working hours and underpayment: a fast-food restaurant in Limerick was ordered by the WRC to pay over €57,000 in compensation to a migrant worker who worked up to 18-hour days without receiving the national minimum wage, was dependent on his employer for accommodation and immigration status, and had to “beg for money” for basic needs. Evidence before the WRC showed he worked in a shop by day and as a delivery driver by night, sometimes logging more than 115 hours per week across several of his employer’s businesses without proper pay.
Key Takeaways for Irish Businesses
Virtually every company that manufactures, imports, or sells products in Ireland will need to be aware of this new law. The forced labour ban is cross-sectoral and applies to businesses of all sizes, from small importers to large multinationals. Irish business and foreign companies doing business in Ireland, should now begin to fortify their operations against forced labour enforcement risks.
Practical steps and considerations to ensure compliance include:
- Updating compliance and training programmes: Governance and training programmes should be updated to educate procurement teams, in-house counsel, risk managers, and senior leadership on their obligations.
- Supply-chain mapping: Conducting supply-chain mapping to identify any products or parts that may fall under the forced-labour import ban.
- Due-diligence: Incorporating due-diligence measures into procurement, contracting and supplier oversight.
Conclusion
In an era of increasing regulatory and consumer focus on the protection of human rights, Irish businesses can transform this new compliance challenge, with the right advice and preparation, into an opportunity to strengthen trust and sustainability in their global supply chains.
For more information, please contact John Gaffney or Shane Costelloe or your usual contact in Beauchamps LLP.