Relevant for: buyers and category managers in Dutch manufacturing (machinery, metals, high-tech) who buy steel, aluminium or composite products from outside the EU and are renewing or tendering contracts for 2027.

The European Commission adopted the guidelines for the EU forced labour ban on 26 June 2026. The ban applies from 14 December 2027 to products made wholly or partly with forced labour. Under CBAM, missing evidence can already cost money: without actual emissions data verified by an accredited verifier, the importer falls back on default values with a mark-up. For iron and steel, that is 10% in 2026 and 20% in 2027. When renewing or tendering for 2027, set out what evidence your supplier provides per delivery and who pays if it is missing.

What is actually happening

Two European regulations turn evidence on origin and production into a condition for market access or into a cost item. Each works in its own way.

Forced labour ban: fixed start date, guidelines adopted

Regulation (EU) 2024/3015 entered into force on 13 December 2024. The ban applies from 14 December 2027. The European Commission adopted its guidelines as document C(2026) 4386 on 26 June 2026.

According to the guidelines, the ban applies to all products made with forced labour, regardless of origin, type or sector. It covers products placed on the EU market, made available on it or exported. Products made only partly with forced labour are also covered. It does not matter whether the forced labour takes place at your own site or anywhere earlier in the supply chain. The Commission calls due diligence (structured supply chain investigation) a tool for complying with the regulation.

The ban works through investigation. A competent authority must establish, on the basis of credible evidence, that forced labour has been used. Missing supplier evidence is therefore not a ban in itself. During an investigation, however, an authority can request information about your supply chain and your approach. If you cannot provide it, or only partly, your position is weakened.

Products produced or imported into the EU before 14 December 2027 are also covered if they are still made available on the market from that date. Products already with the end user fall outside the scope. Law firm Bird & Bird points out that the guidelines are expressly non-binding. They create no new obligations. According to TrusTrace, which sells traceability software itself, the Commission also launched a Forced Labour Single Portal and a risk database.

CBAM: missing evidence can cost money

The definitive CBAM regime has been running since 2026. The German authority DEHSt describes the importer's choice. The importer calculates embedded emissions using the installation's actual values, verified by an accredited verifier. Or it uses the European Commission's default values.

For iron and steel, those default values include a mark-up of 10% in 2026, 20% in 2027 and 30% from 2028. The Commission intends to review the values and mark-ups by December 2027.

Law firm Reed Smith sets out two practical points. An accredited verifier is only needed if you use actual values. And the sale of CBAM certificates starts in February 2027, for the emissions of imports in 2026. According to the European Commission, each quarter of 2026 has its own certificate price, which applies to imports in that quarter: €75.36 for Q1 and €75.28 for Q2.

Structural drivers

Orbecta analysis: both regulations increase the importance of demonstrable information about the product and the supply chain, but in different ways. Their start dates are fixed. Under CBAM, missing evidence can cost money: the importer falls back on a default value including a mark-up. Under the forced labour ban, an authority must establish that forced labour has been used. Missing evidence is not a ban in itself, but weakens your position if an investigation is opened.

The mark-up on default values for iron and steel rises from 10% in 2026 to 20% in 2027 and 30% from 2028. For contracts running through 2027 and 2028, the mark-up of those years counts, not today's. Whether a supplier with verified data comes out cheaper depends on the actual emissions of its installation compared with the default value. You need to ask each supplier for that.

Who is directly affected

Directly, now: companies that themselves import CBAM goods from outside the EU, such as steel or aluminium, for example via Rotterdam or Antwerp. The 50-tonne threshold applies to all CBAM goods combined per calendar year, not per product. Those above it bear the CBAM costs and choose between actual values and default values. Those who stay below it in total fall outside CBAM.

Directly, from 14 December 2027: every company that places products on the EU market or makes them available. That includes distributors and products of EU origin, because the ban looks at the entire supply chain.

Indirectly: those who buy steel or aluminium from an EU stockist or trader that imports itself. The CBAM costs then reach you through the selling price or a surcharge.

Probably not directly: buyers who only purchase steel and aluminium from EU producers. No CBAM applies to those flows. They will still be affected if a supplier starts using semi-finished products from outside the EU, or switches to a non-EU source at renewal.

The second-order effect

Orbecta analysis. The chain plays out in three scenarios.

Scenario 1: no verified installation data in 2027. This applies if your non-EU steel supplier cannot make verified emissions data per installation available for 2027. In that case, the importer falls back on the default value including the 20% mark-up. The extra certificate costs reach you through the price or a CBAM surcharge. Suppliers with verified, lower actual values may then have a cost advantage and use it in the negotiation. The indicator: the share of your non-EU tonnage with verified actual values.

Scenario 2: stock crossing the 14 December 2027 line.