Response to the consultation on guidelines for the implementation of the EU rules on forced labour

In its response, SolarPower Europe highlights several priorities including the following ones:

• The guidelines should provide clear, practical and sector specific guidance for the implementation of the EU Forced Labour Regulation, ensuring legal certainty, procedural clarity and consistency with existing EU due diligence legislation, including the Corporate Sustainability Due Diligence Directive and the Batteries Regulation.
   
• The EU Commission should clarify the types of evidence and documentation that economic operators may provide and that competent and customs authorities should accept, taking into account the multi stage, multi actor and cross border nature of solar supply chains, and allowing for a risk based and proportionate approach.

• The guidelines should recognise documentation generated by credible industry schemes and independent third party audits as relevant evidence for assessing compliance, including certification and traceability systems based on independent verification.

• Clear guidance should be provided on forced labour due diligence best practices, including risk identification and assessment, training, reporting mechanisms, remediation, and disengagement as a measure of last resort, in line with international standards.

• The EU Commission should support implementation through complementary practical resources, including FAQs, procedural guidance and clarity on investigations, penalties and operational aspects of the Regulation.

• Training and capacity building for competent authorities, customs authorities and economic operators should be prioritised to support consistent and predictable enforcement across Member States.

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