EU Forced Labour Regulation: Due Diligence Guidelines

SolarPower Europe’s key recommendations on the Forced Labour Regulation Due Diligence Guidelines:

• SolarPower Europe is fully committed to the eradication of forced labour and related human rights abuses. To achieve this goal, the guidelines should provide a clear and practical route-to-compliance for economic operators, competent authorities and for customs authorities. 

• SolarPower Europe advocates for the development of sector-specific guidelines under the Forced Labour Regulation (FLR), recognising that each sector has distinct supply chains and challenges. 

• In conjunction with 3rd party verified compliance with CSDDD, SolarPower Europe recommends the recognition of existing sector-specific industry schemes and multi-stakeholder initiatives, such as the Solar Stewardship Initiative (SSI) or equivalent, as reference points and as a tool for economic operators and competent authorities to support the implementation of the FLR. 

• SolarPower Europe recommends a coordinated approach with the CSDDD, Corporate Sustainability Reporting Directive (CSRD), as well as ensuring consistency with the Battery Regulation and the EU Conflict Minerals Regulation. This would help monitor and mitigate risk of human rights impacts, while ensuring high Environmental, Social, and Governance (ESG) performance across the solar sector.

• SolarPower Europe recommends the creation of a list of documents and transparent processes that competent and custom authorities require from economic operators to prove compliance with the FLR. However, this list should remain flexible, serving as a guideline rather than a strict, exhaustive requirement.

• SolarPower Europe calls on the European Commission for a fast-track process in establishing their high-risk list to allow supply chains to take adaptive measures – where necessary – as fast as possible and in due time for the entry into force of the legislation in 2027. 

• SolarPower Europe advocates for a tailored approach to equip EU competent authorities with the necessary resources and expertise for the effective and smooth implementation of the Forced Labour Regulation, ahead of its entry into force.