Forced labor due diligence: what fashion brands now ask leather suppliers
Forced labor due diligence in fashion is shifting from company-level policies to shipment-level proof. The EU Forced Labour Regulation applies from 14 December 2027 and can ban products regardless of who imports them, while the EU's broader due diligence law has been narrowed to the largest companies. For leather suppliers, the practical result is the same either way: buyers want maps, records and evidence they can hand to an authority.
The rules differ in design. Some impose duties on large companies; others act on products at the border. Brands of every size feel the second kind, because a detained shipment is a detained shipment.
The EU: a product ban with no size threshold
Regulation (EU) 2024/3015 prohibits placing on the EU market, or exporting, products made wholly or partly with forced labor. It applies from 14 December 2027, including to products made or imported earlier that are still available on that date. A decision that finds a breach requires withdrawal and disposal of the products, and the prohibition binds any operator dealing in them, not just the one investigated.
The regulation does not impose a formal due diligence obligation, but the Commission's guidelines, published on 26 June 2026, use the OECD due diligence steps as the benchmark. Law-firm summaries of the guidelines list what authorities may ask for: due diligence procedures and risk measures, multi-tier supply chain maps, purchase orders, invoices, shipping records, facility details and worker-related information. Failing to cooperate can weigh against an operator, and due diligence is evidence, not a safe harbor: the ban turns on how the product was made.
The CSDDD after the omnibus
The Corporate Sustainability Due Diligence Directive was substantially cut back. The Omnibus I directive, formally adopted by the Council on 24 February 2026, raised thresholds to more than 5,000 employees and more than EUR 1.5 billion in worldwide turnover for EU companies, and EUR 1.5 billion in EU turnover for non-EU companies. Transposition is due by 26 July 2028 and compliance from 26 July 2029. Companies focus on the most likely and severe impacts, may prioritize direct business partners where risks are otherwise equal, and should ask partners with fewer than 5,000 employees for information only when it cannot reasonably be obtained another way.
Few leather goods brands will be directly in scope. Their largest retail customers may be, and those customers pass questions down the chain.
The US: border enforcement and a tariff link
Section 307 of the Tariff Act of 1930 bars imports of goods made wholly or partly with forced labor. US Customs and Border Protection can detain shipments under withhold release orders, and importers then have a limited window to prove admissibility or re-export.
Trade policy now overlaps. USTR's final Section 301 notice of 23 July 2026 followed investigations into the failure of 60 economies to impose and effectively enforce prohibitions on imports made with forced labor. India was placed in the 10% tier after amending its Foreign Trade Policy in July 2026 to allow such import bans, and the tariff applies on top of normal duty from 24 July 2026 (see US Tariffs on Leather Goods from India in 2026: What US Brands Need to Know). The action is being challenged at the US Court of International Trade.
What this means for brands sourcing leather goods
| Document | Purpose |
|---|---|
| Supply chain map per style: assembly, tannery, key components | Shows where risk could sit and who to audit |
| Purchase orders and invoices linked to production lots | Proves which inputs went into a shipment |
| Social audit reports and corrective action records | Evidence of monitoring and remediation |
| Recruitment, wage and working-hours policies | Addresses common forced-labor indicators |
| Subcontracting policy and approved subcontractor list | Closes the most common visibility gap |
Leather supply chains have more stages than most finished goods, so the tannery link deserves the same attention as the assembly unit. Certifications help (see Leather Manufacturer Certifications Explained: LWG, ISO, Sedex and What to Ask Your Supplier), but authorities ask about products, not logos. Brands should agree in contracts how quickly suppliers must produce records on request.
Frequently asked questions
When does the EU Forced Labour Regulation apply?
From 14 December 2027. It covers products placed on the EU market or exported, including stock already in distribution on that date. Check the official text and Commission guidelines for detail.
Is my brand in scope of the CSDDD?
Only if it exceeds the revised thresholds of more than 5,000 employees and EUR 1.5 billion in turnover, or EUR 1.5 billion in EU turnover for non-EU companies. Your larger customers may still request similar information.
What documents should a leather supplier have ready?
A style-level supply chain map, lot-linked purchase records, social audit and remediation records, and clear subcontracting rules. These serve EU, US and customer requests alike.
Conclusion
The legal duties are narrowing for most companies, but product-level enforcement is widening. That makes documentation the real compliance asset in leather supply chains. Verify current rules against official sources before relying on them.