Part 1: How YESS Helps Brands Navigate the Upcoming EU Forced Labour Regulation
By: Aidan Kelly
This is the first part of a two-part blog series. The European Union is advancing a new era of supply-chain accountability. With the Forced Labour Regulation now adopted and slated to become fully applicable in December 2027, companies selling products in the EU will need to ensure those products were not made—in whole or in part—with forced labour, or face having them banned from the EU market. These evolving requirements make robust, risk-based compliance systems more important than ever. That’s where YESS: Yarn Ethically & Sustainably Sourced™ comes in, offering a practical framework for brands and their sub-suppliers to manage forced-labour risks effectively and closer to where the harm is occurring.
Understanding the EU Forced Labour Regulation
The EU Forced Labour Regulation introduces a ban on products made with forced labour, ensuring they cannot be sold within or exported from the EU market. This prohibition applies to all products and their components, regardless of where they were manufactured.
“Forced labour” is defined using the International Labour Organization’s (ILO) definition—referring to any work performed under threat or coercion, and without voluntary consent—making the regulation’s reach global. The ILO updated its Forced Labour Indicators in November 2025, providing further clarity on the warning signs companies should look for across their supply chains.
Although the Regulation entered into force upon adoption in 2024, it will only become fully applicable in December 2027. This transition window allows companies to assess current practices, identify risks, and build due diligence processes before enforcement begins. However, law firms and compliance experts emphasize that waiting until 2027 is not a safe play.
The EU Commission is mandated to publish guidance on risk indicators and a product database by June 14, 2026. Once that guidance is published, we will release part two of this series — a practical look at how YESS supports importers and their supply chain partners in meeting the regulatory requirements.
Forced Labour Risks in Cotton
Cotton supply chains face elevated forced labour risks due to the large amount of manual labour, slim profit margins, and complex global production networks.
Because the Regulation applies to products made in whole or in part with forced labour, even a small amount of tainted cotton fiber (which can be introduced at any stage from aggregators, gins, and traders, to spinning and fabric mills), can render a product non-compliant. This makes implementing due diligence and risk mitigation across all tiers of the cotton supply chain essential.
YESS Supports Mills with Compliance and Risk Management
YESSTM was created by Responsible Sourcing Network (RSN)TM to eliminate forced labour from cotton supply chains by equipping spinning mills and fabric mills with a practical risk-based due diligence framework, capacity building, and annual assessments.
1. A Practical OECD-Aligned Framework
YESS utilizes the globally recognized OECD Due Diligence Guidance for Responsible Supply Chains to identify and manage forced labour risks. This alignment gives brands confidence that their practices are rooted in an internationally accepted framework. Compliance experts note that companies with programs aligned to the OECD Due Diligence Guidance, or UN Guiding Principles on Business and Human Rights (UNGPs) should be in a strong position to meet the regulation’s expectations.
2. Focus on Key Control Points
Spinning and fabric mills are key “mixing points” where raw cotton from multiple origins converges, and where traceability to origin can be lost. YESS offers standards, training, procedures, and criteria to help assess, prevent, mitigate, and remediate forced-labour risk in their supplier base and with their raw material inputs.
3. Know Your Supplier (KYS) and Know Your Material (KYM)
YESS’s KYS and KYM frameworks require participating mills to verify and pre-approve suppliers, determine material risk levels, track cotton origin, identify red flags, and maintain comprehensive documentation. In addition, to maintain YESS conformance, mills need to annually review and publicly share their responsible sourcing policy and due diligence report. Brands can reference this rigorous due diligence system to demonstrate proactive risk management, in the middle of their supply chain, if regulators ask for proof of compliance.
4. Continuous Improvement
Unlike one-off inspections, YESS promotes a robust training and management systems approach that builds capacity and minimizes risk over time, with a focus on addressing the greatest risks first. Mills start with e-learning courses that walk them through policy and procedure development, with a goal of cascading due diligence through their management systems. They then undergo annual assessments to evaluate progress and refine practices, aligning with broader expectations for sustained due diligence. Post-assessment, mills are supported by RSN to address any weak or non-conformant management systems.
Enhancing Brand Preparedness
While the Regulation’s enforcement mechanisms are not fully operational yet, brands that join and integrate YESS into their existing procurement systems now will be in a stronger position to:
Show documented, risk-based due diligence aligned with international standards
Demonstrate traceability through the intermediary tiers
Engage suppliers proactively on forced-labour risks
Build resilience ahead of regulatory scrutiny
Conclusion
The EU Forced Labour Regulation marks a major step forward in global efforts to eliminate forced labour. YESS provides a credible, practical, and internationally aligned roadmap for brands and mills to manage forced-labour risk with confidence, helping companies prepare now to avoid future disruptions, and uphold ethical sourcing commitments that go beyond regulatory minimums. Keep an eye out for part two of this blog series, which will illustrate how brands and mills can leverage YESS to maximize efficiency and impact in the middle of the supply chain.