UK Proposes Mandatory Supply-Chain Checks and Forced-Labour Product Removals

The UK government is developing legislation that would require mandatory human-rights due diligence by UK businesses with global turnover above £350 million and overseas businesses with UK sales above the same threshold. If forced labour is identified and a company has not completed the required checks, affected products could be removed from store shelves, warehouses, and online marketplaces. The proposal therefore reaches beyond corporate reporting: it could directly affect whether goods remain available in UK supply chains and commercial channels.

Business Secretary Jonathan Reynolds set out the plans in a letter to the Business and Trade Committee of the UK Parliament. He described the existing UK framework as “fragmented and overly reliant on voluntary action and reporting measures.” Reynolds acknowledged that the Modern Slavery Act, introduced in 2015 and “world leading at the time,” has not kept pace with evolving international standards and legislative practice, leaving the UK out of step with G7 partners and other major trading economies. The proposal signals a move toward more enforceable supply-chain expectations, but the government has not announced a delivery timetable or provided details on the proposed regulator.

For government procurement teams and contractors that buy or supply goods, the central operational issue is whether suppliers can produce credible information about sourcing, traceability, and human-rights checks. A product-removal mechanism could create availability gaps, interrupt supplier continuity, and complicate performance for contracts dependent on goods moving through complex international supply chains. Organizations above the proposed thresholds may face direct obligations; smaller suppliers could also encounter increased information requests from larger customers seeking to demonstrate that due diligence was conducted across relevant supply chains.

The government says an empowered regulator would provide a “targeted mechanism” for addressing serious abuses and protecting responsible businesses from unfair competition. Reynolds said the package would “safeguard the competitiveness of responsible businesses, strengthen confidence in UK markets and help ensure that goods linked to forced labour do not reach UK consumers.” The proposal also sits within wider international pressure: the source reports that the United States proposed tariffs in June on 60 economies, including the UK, over alleged failures to stop goods made with forced labour. In Northern Ireland, the government intends to apply the EU’s forced-labour regulation under the Windsor framework, under which goods made with forced labour can also be withdrawn from the market.

• Thresholds: Proposed due-diligence duties would apply to UK businesses with global turnover above £350 million and overseas businesses with UK sales above £350 million.
• Potential enforcement consequence: Products could be removed from stores, warehouses, and online marketplaces if forced labour is identified and required checks were not carried out.
• Procurement implication: Buyers and contractors should assess supplier traceability, documentation, and ability to provide human-rights due-diligence information.
• Continuity risk: Product withdrawals could affect availability and supplier continuity, including for organizations relying on goods sourced through multi-tier supply chains.
• Regulatory uncertainty: The government has not announced an implementation timetable or details about the regulator, leaving the proposal at a planning and readiness stage.
• Existing framework: Reynolds characterized the current UK approach as “fragmented and overly reliant on voluntary action and reporting measures,” and said international standards have evolved since the Modern Slavery Act was introduced in 2015.
• Committee scrutiny: Liam Byrne, chair of the Business and Trade Committee, called the UK’s weaker protections against forced-labour imports an “outrage” and urged clarity on delivery timing and regulator resources.
• International context: The source notes a US proposal for tariffs on 60 economies, including the UK, and planned application of the EU forced-labour regulation in Northern Ireland under the Windsor framework.
• Companies cited in related scrutiny: Shein, Boohoo, and Dyson are named in the source data; the article reports that the committee warned the Financial Conduct Authority in July 2025 against easing listing rules for Shein over supply-chain labour concerns.
• Action now: Use the proposal period to map higher-risk sourcing, establish evidence of supplier checks, identify gaps in traceability, and prepare for possible contractual or compliance requests from larger customers.