The EU Forced Labour Regulation

Produced in partnership with Nikolay Mizulin of Mayer Brown , Paulette Vander Schueren of Mayer Brown , Dr. Dylan Geraets of Mayer Brown , Ivan Baranenko of Mayer Brown and Agnieszka Nosowicz of Mayer Brown
Practice notes

The EU Forced Labour Regulation

Produced in partnership with Nikolay Mizulin of Mayer Brown , Paulette Vander Schueren of Mayer Brown , Dr. Dylan Geraets of Mayer Brown , Ivan Baranenko of Mayer Brown and Agnieszka Nosowicz of Mayer Brown

Practice notes
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Regulation (EU) 2024/3015 on prohibiting products made with forced labour on the Union market and amending Directive (EU) 2019/1937 (the EU Forced Labour Regulation or EUFLR) lays down a prohibition to place or make available on the Union market domestic or imported products made with forced labour, or to export such products, and the obligation to ensure that such products are withdrawn from the EU market.

Timeline

This table includes the key legislative steps leading to the adoption of the EUFLR.

What’s happeningWhen
Date of applicationThree years from entry into force—14 December 2027, apart from the provisions in the Articles listed below which apply from the date of entry into force of the EUFLR—13 December 2024:5(3)—12-month period for Member States to notify contact details and areas of competences of competent authorities (see: Competent authorities7—Information and communications systems (see: Information and communications systems8—Database of forced
Nikolay Mizulin
Nikolay Mizulin

Partner and co-lead of the firm’s International Trade Practice, Mayer Brown


Nikolay Mizulin is Co-Lead of Mayer Brown's International Trade Product Group. He advises clients on all aspects of international and EU trade law, with particular emphasis on trade remedies, WTO Dispute Settlement, customs and sanctions.

Nikolay has represented corporations and governments in anti-dumping, safeguard, and anti-subsidy cases before EU institutions as well as before the investigating authorities of Brazil, China, India, the US, and other countries. His experience covers all stages of the proceedings, from preparing questionnaire responses to challenging measures before the courts. Nikolay has been involved in several high-profile WTO disputes, providing assistance to governments as well as private sector.

In his regulatory practice, Nikolay advises private companies in matters relating to the application of EU sanctions. He assists clients in complying with customs regulations and advises on the EU's forthcoming Carbon Border Adjustment Mechanism, measures prohibiting products made by forced labour as well as other measures affecting supply chains.

In addition to his native Russian, Nikolay speaks fluent English and Spanish.

Paulette Vander Schueren
Paulette Vander Schueren

Partner, Mayer Brown


Paulette Vander Schueren is a senior partner in Mayer Brown's International Trade Product Group in Brussels, after leading the team for well over a decade.

Chambers Global stated that “Paulette Vander Schueren is consistently singled out for her depth of experience in this field, and is described by sources as "one of the best customs and trade lawyers in the world” and Chambers Global 2021 mentions that clients value Paulette for her “enormous wealth of experience, eye for the larger detail.” Chambers Europe 2022 states that sources deem her to be "very wise and a pleasure to listen to," further noting that "she is extraordinary in many respects." The International Who's Who of Business Lawyers - Trade & Customs lists her as a Global Elite Thought Leader. Paulette is also recognized as part of the Hall of Fame in Legal 500 EMEA – Customs, Trade, WTO and Anti-Dumping in Belgium.

She advises clients on all aspects of international and EU trade and customs law, with particular emphasis on trade remedies, customs and export control and sanctions as well as EU decision-making procedures having an impact on trade.

She represents and advises clients in trade remedy cases before the EU institutions and outside the EU, including on anti-dumping, subsidies, safeguard and, in the EU, on Trade Barrier Regulation matters.

She advises foreign governments on the implementation and interpretation of trade remedy laws and also advises private and governmental clients on the negotiation and interpretation of international and bilateral agreements concluded by the EU as well as on WTO issues. Paulette has also been involved and handled WTO dispute settlement proceedings.

Paulette represents clients in a wide range of customs matters involving inter alia tariff classification, including before EU and EU Member State authorities as well as the World Customs Organization (the "WCO") and authorities outside the EU. She represents clients on customs valuation matters involving EU and WTO/WCO provisions before EU, EU Member State and third country authorities. She advises on economic tariff regimes such as inward processing and processing under customs control or duty suspensions and tariff quotas. She counsels clients on EU and international origin rules as well as origin labelling and on the EU's General System of Preferences.

Paulette represents and advises private companies in relation to the interpretation of EU and international provisions on export controls and economic sanctions and on the implementation of these provisions by EU Member States, both as regards ad hoc issues and the drafting of compliance documents or contractual provisions. She also advises on the implications of the EU’s anti-boycott provisions. In these matters, Paulette and her colleagues in Brussels work closely together with their colleagues in the US and the UK who are experts in these matters.

Paulette’s EU Regulatory experience includes EU's harmonization legislation and its implementation in the EU Member States, including technical regulations and standards, safety regulations and provisions affecting the marketing of goods (for example, sales promotion guarantees), as well as excise, VAT and environmental provisions. With the entry into force of the Lisbon Treaty in the EU, Paulette has also counselled clients on EU institutional matters and the balance of powers.

Paulette and her colleagues advise also on a number of novel regulatory issues including forced labour, environmental issues including deforestation, CBAM and ETS, foreign direct investment, third country subsidies regulations, supply chain due diligence requirements or other ESG related matters.

Paulette has been involved in numerous international trade disputes and appeared before the European Commission as well as the European Courts. She has also appeared in and counsels on WTO dispute settlement.
Prior to joining Mayer Brown in 2005, Paulette was co-head of the International Trade team at another prominent law firm where she practised in the same field since 1981.

Dylan Geraets
Dr. Dylan Geraets

Counsel, Mayer Brown


Dylan advises clients on a wide range of global trade issues. His practice focuses on international dispute settlement, trade defence measures, customs rules, trade negotiations, sanctions, and export controls. Dylan represents clients in WTO dispute settlement proceedings and proceedings before the Court of Justice of the European Union. He is recognized by The Legal 500 as a “Key Lawyer” in 2023, as well as by Who’s Who Legal (WWL) in 2022 as “Recommended: Trade & Customs.”

Dylan is experienced in advising and representing both multinational companies and sovereigns in respect of proceedings before WTO panels and the Appellate Body. In addition, he assists clients across industries in trade remedy investigations, such as anti-dumping and safeguard investigations. In this context, he has been involved in several cases before the Court of Justice of the European Union.

On a daily basis, Dylan advises on the interpretation of rules and procedures impacting trade in goods and services. This includes the provision of advice on customs matters such as rules of origin, tariff classification, customs valuation, and the applicability of special custom procedures. In this regard, he regularly counsels clients in respect of proceedings before customs and other relevant authorities of EU Member States.

Dylan regularly advises on the implications of the EU’s export control regime in relation to certain dual-use goods and other sanctioned items. In addition, he guides clients in respect of their day-to-day sanctions compliance efforts under the EU sanctions regimes, as well as with respect to the implementation of sanctions imposed by the United Nations.

Dylan also regularly advises on novel regulatory issues, including ESG-related matters such as supply chain due diligence, forced labour, and environmental issues including deforestation, the EU’s Carbon Border Adjustment Mechanism (CBAM) and Emissions Trading Scheme (ETS), as well as EU instruments adopted or negotiated as part of the push for “Strategic Autonomy”, such as the FDI Screening Regulation, the Foreign Subsidies Regulation, and the Anti-Coercion Instrument.

In 2022, Dylan was appointed as Professor of International Trade and Investment Law at the University of Antwerp. He is a Member of the Academic Board of the ELSA John H Jackson Moot Court Competition on WTO Law and of the Society of International Economic Law (SIEL). Dylan regularly speaks at international conferences, such as the SIEL Global Conference and the BIICL Annual Conference on WTO law. His research has been published in the Journal of International Economic Law, the World Trade Review, the Journal of World Trade, and the Global Trade and Customs Journal.

Prior to joining Mayer Brown in 2015, Dylan was a PhD candidate at KU Leuven (Belgium). His doctoral dissertation entitled “Accession to the World Trade Organization: A Legal and Normative Analysis” was published in 2018 by Edward Elgar Publishing. In early 2016, Dylan gained valuable experience in the Appellate Body Secretariat of the WTO. Earlier in his career, he served at the Ministries of Foreign Affairs and Economic Affairs of The Kingdom of The Netherlands as a trade policy advisor based at the Permanent Representation of the Kingdom of the Netherlands to the WTO in Geneva.

Dylan is fluent in English and German in addition to his native Dutch.


Ivan Baranenko
Ivan Baranenko

Associate, Mayer Brown


Ivan, an associate in Mayer Brown's International Trade group in Brussels, advises clients on a wide range of issues in the field of international trade, with a focus on trade remedies (including anti-dumping, anti-subsidy, and safeguard investigations), EU sanctions, customs rules, and WTO law.

Ivan is active in representing clients in trade defense investigations before the investigating authorities of the EU, the US, Brazil and other jurisdictions. He also advises on market access issues, government trade policies, and internal compliance investigations in the sphere of sanctions and customs law.

Prior to joining Mayer Brown, Ivan worked for a top-tier law firm in Kyiv (Ukraine), where he obtained extensive experience in international trade law, including regulatory issues, trade remedies, and WTO law.

Ivan is fluent in English in addition to his native Ukrainian and Russian.

Agnieszka Nosowicz
Agnieszka Nosowicz

Associate, Mayer Brown


Admitted to the Paris Bar, Agnieszka is an associate in the International Trade group of the Brussels office.

Agnieszka advises clients on a broad range of issues related to trade, customs, market access and EU regulatory issues, with a special focus on trade remedies (anti-dumping, anti-subsidy and safeguard investigations), as well as on sanctions and export control matters. She also assists clients in disputes before European Courts.

Prior to joining Mayer Brown in 2023, Agnieszka worked for a leading law firm in international trade in Brussels, where she gained extensive experience, especially in the area of trade remedies in the EU and in other third countries (Morocco, Gulf Cooperation Council, Brazil).

Agnieszka speaks English and French, in addition to her native Polish.

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Jurisdiction(s):
European Union

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