The EU Forced Labour Regulation (Regulation (EU) 2024/3015) bans placing products made with forced labour on the EU market, making them available there, and exporting them. It covers all products in all forms and applies from 14 December 2027.

It is an obligation of result: enforcement judges whether the product is free of forced labour, not whether a due-diligence process was followed. There is no grandfathering, so stock already in warehouses is in scope from day one. Investigations are risk-based and prioritised by scale and severity, volume on the market, share of the suspect input in the final product, and operator size. Non-cooperation counts against the operator, and state-imposed forced labour is treated as severe.

Documentation requirements are not yet clearly defined. Information is requested case by case. The European Commission's examples include product identification, supply chain structure and actors, facility and location information, transactional and logistic records, and production and capacity evidence. Until clearer requirements are published, Product Mapping is the core feature; Order Tracing is optional and may become necessary.

(1) Goal

Start product mapping (supported by supply chain mapping) so you can show, per product, who made it and where, and can produce that evidence on demand when an authority investigates. This includes legacy stock.

(2) Kick-start minimum: what IT needs to deliver first

To start Product Mapping (core): the product master (name, code, product type, finished good vs. component), main material composition, and the T1 supplier per product with a contact email.
To start Supply Chain Mapping: only the T1 supplier list: legal name, country, address, facility process, contact email.
Purchase orders are not needed to start. They only come in if Order Tracing is added, for example for the highest-risk products or once documentation requirements are clearer.

(3) Features needed

#	Feature	Role	Why it is needed
1	Product Mapping	Core	Product-level evidence: product identification, supply chain structure and actors, facility and location per product.
2	Product Library + Material Composition	Core	The products to map. Composition shows the share of a suspect input in the final product, one of the prioritisation criteria.
3	Network (supplier master data)	Core	Facility and location information for every party.
4	Supply Chain Mapping	Important	Supplier-level information beyond T1 across your whole network, not tied to one product.
5	Questionnaires	Important	Working conditions at site level and your actions to identify, prevent and remediate forced-labour risk.
6	Risk Management	Supporting	Forced-labour risk assessment by supplier and region to decide where to go deeper.
7	Audit Management + CAPA	Supporting	Turns audit findings into trackable actions. Note: social audits in areas with state-imposed forced labour are not credible evidence.
8	Entity Screening	Supporting	Screens parties against restricted-party and adverse-media lists.
9	Order Tracing	Optional (to be decided)	Transactional and logistic records per purchase order. May become necessary once the EU publishes clearer documentation requirements.

(4) What an authority may ask for, and where it lives in Retraced

European Commission example	Retraced feature
Product identification	Product Library
Supply chain structure and actors	Product Mapping, Supply Chain Mapping
Facility and location information	Network, Product Mapping
Bills of materials	Material Composition, BOM
Transactional and logistic records	Order Tracing (optional)
Production and capacity evidence	Order Tracing documents, Questionnaires
Working conditions at the site	Questionnaires, Audit Management
Actions to identify, prevent, mitigate and remediate	Risk Management, CAPA

(5) Data points per feature

Network (supplier master data)

Companies are read-only in the Public API (GET /api/v2/companies/). Suppliers are onboarded in Retraced (network import, data migration or invitation), not via the API.

Data point	Requirement	Note
Supplier legal name	Mandatory
Country	Mandatory
Address (street, city)	Mandatory
Facility process(es)	Mandatory	e.g. Spinning, Weaving, Sewing.
Contact person and email	Mandatory	Needed to invite suppliers.
Identifiers: OS Hub ID, GLN, DUNS, VAT ID, commercial register number, HIGG ID	Recommended	Improve matching and screening.
Certificates, audits	Optional	Can be collected via questionnaires.

Product Mapping

Data point	Requirement	Public API v2 field	Note
Products to map	Mandatory	— (products via POST /api/v2/styles/)	Product Mapping itself is not in the Public API; requests are created in Retraced.
T1 supplier and facility process	Mandatory	— (mainSupplier on the style helps)
Instructions (expected mapping depth per material)	Recommended	—	e.g. raw material for cotton, wool and down; spinner for other fibres. Communicate this per request.
Upstream suppliers per tier, processes, countries, components	Supplier-provided

Product Library + Material Composition

Data point	Requirement	Public API v2 field	Note
Product name	Mandatory ⚙️	`name`
Product code	Mandatory ⚙️	`codes[]` (codeId + codeValue)
Product type	Mandatory ⚙️ (top-level style only)	`styleTypeId`
Finished good vs. component	Mandatory ⚙️ (top-level style only)	`isComponent`
Main supplier (T1)	Mandatory	`mainSupplier`	Needed to send Product Mapping requests.
Your own product ID	Recommended	`externalId`	Unique across product levels.
Composition header (name, product, main flag)	Mandatory ⚙️	`name`, `link.styleId`, `link.isMainMaterial`	POST /api/v2/material-headers/
Fibre and percentage	Mandatory ⚙️	`rawMaterialId`, `percentage` (+ materialHeaderId, styleId)	Identifies high-risk materials.
Season, collection	Optional	`seasons[]`, `collections[]`	Useful to scope the first mapping wave.
Fibre country of origin	Optional	`countriesOfOrigin[]`	Usually supplier-provided.

Supply Chain Mapping

Data point	Requirement	Note
T1 supplier list with contact emails	Mandatory	From Network. Enough to start.
Known lower-tier suppliers	Optional	Speeds up the mapping.
Upstream suppliers and their processes	Supplier-provided

Questionnaires

No IT data needed beyond the Network contacts. The content (legal information, labour conditions, recruitment practices, audits) is defined in the questionnaire template.

Order Tracing (optional, to be decided)

Only needed if you add purchase-order-level evidence. The data points are the same as in the UFLPA article in this collection. Mandatory: order number, buyer, supplier and order lines (product, quantity, unit). Recommended: facility processes, the document set, shipment reference, line weight in kg, and order and delivery dates.

In the Public API, only order number, buyer and supplier are required ⚙️ (plus product, quantity and unit per line); the attachment template falls back to the company default.

Entity Screening

Data point	Requirement	Note
Legal name, country, address	Mandatory	From Network.
Registration identifiers	Recommended	Better match accuracy.

Risk Management

Data point	Requirement	Note
Supplier country and facility process	Mandatory	From Network.
Audits, certificates, questionnaire answers	Optional	Improve the score.

Data requirements: EU Forced Labour Regulation (EUFLR)