UK to pull forced labour goods from shop shelves: what the law means

The government has told MPs that goods made with forced labour will be pulled from sale in Great Britain, from shop shelves, warehouses and online marketplaces alike, under a new law that will make the largest retailers check their supply chains for human rights abuses. Business Secretary Jonathan Reynolds set out the plan in a written ministerial statement to the Commons on 4 November 2026, and the detail reached the public on 9 November when his letter to the Business and Trade Committee was reported by the Times, LBC, Business Live and Business Matters.

The duty will apply to UK businesses with a global turnover above £350 million and to overseas businesses whose UK-generated turnover passes £350 million. That second test is the one that matters most for online shopping, because it reaches platforms and brands that sell heavily into Britain without being based here. What it does not yet have is a start date, a named regulator or a published bill.

What exactly has the government announced?

The announcement came in two steps. On 4 November 2026 Reynolds, as Secretary of State for Business, Innovation, Science and Trade, laid a written ministerial statement (reference HCWS454) setting out the results of a review of the UK’s approach to what Whitehall calls responsible business conduct. Five days later his letter to the Commons Business, Innovation, Science and Trade Committee, which had pressed for stronger rules for almost two years, became the basis of the weekend and Monday coverage that framed the plan as a ban on forced labour goods in British shops.

The written statement is blunt about the current position. It says the review “found the UK’s current framework for preventing forced labour to be fragmented and overly reliant on voluntary action and reporting measures”. It adds that while the Modern Slavery Act 2015 “was world leading at the time of its introduction”, international standards have since moved on, “leaving the UK out-of-step with G7 partners and other major trading economies”.

The due diligence duty

The first measure is a mandatory human rights due diligence regime. It will apply across the UK for services and in Great Britain for goods. Businesses in scope “will be required to identify, assess and address risks of human rights abuses and labour exploitation within their operations and supply chains”, according to the statement.

The government describes the regime as risk-based and proportionate, and says it will align with two existing international frameworks: the OECD Guidelines for Responsible Business Conduct and the UN Guiding Principles on Business and Human Rights. That matters for retailers already selling into Europe, because the same frameworks sit underneath EU rules, so a single due diligence system could in principle serve both.

The power to pull goods from sale

The second measure is the one that turns the announcement into a shopping story. “Under this due diligence regime, we will introduce powers to be able to remove goods made with forced labour from the Great Britain market,” the statement says. A regulator “will be empowered to investigate businesses suspected of placing such goods on the market and, where due diligence obligations have not been met and forced labour is identified, direct their withdrawal.”

Business Matters reports that Reynolds’ letter to the committee spells out where that withdrawal could bite: products could be removed from store shelves, warehouses and online marketplaces. Business Live quotes the same letter: “We believe this package of measures strikes the right balance: safeguarding the competitiveness of responsible businesses, strengthening confidence in UK markets and helping to ensure that goods linked to forced labour do not reach UK consumers.”

The government will also set up a central guidance hub on GOV.UK with tools and templates for businesses building due diligence processes for the first time. The statement ends with a line aimed squarely at the public: “The British public rightly expect that products sold in the United Kingdom are not tainted by forced labour.”

Which retailers and marketplaces fall inside the £350 million threshold?

Only “the largest businesses, with the capability and leverage to manage these risks within their supply chains” will be in scope, the statement says. In practice that means two tests. A UK business counts if its global turnover is above £350 million. A non-UK business counts if its turnover generated in the UK is above £350 million, which is roughly USD 470 million at current rates (about USD 1.34 to the pound).

The government has not explained how the tests will apply to corporate groups, as the law firm Fieldfisher points out in its analysis of the statement. It is not yet clear, for example, whether a parent company’s turnover is counted, or only that of the entity that places goods on the market. The table below therefore shows published turnover figures for well-known names sold to UK shoppers as an illustration of scale, not as a legal ruling on who is caught.

Business	Published turnover figure	Period	Compared with £350m
Marks and Spencer	£9,255m group sales	Half year to September 2026	Far above, in six months alone
Next	About £6.03bn sales (company guidance)	Year to January 2027	Far above
ASOS	£2,240.3m adjusted revenue	Financial year 2026	Far above
Shein Distribution UK	£2.05bn revenue (Companies House filings, as reported in August 2025)	Calendar year 2024	Far above on UK sales alone
Starbucks Coffee Company (UK)	£556.3m sales	Financial year 2025	Above, though food and drink supply chains differ

The pattern is clear: the national chains and the large online fashion players that dominate UK baskets are comfortably above the line. Recent results show the scale involved; our report on ASOS’s full-year results and its UK sales put its adjusted revenue at more than six times the threshold.

Why overseas platforms are caught

The UK-turnover test is designed for businesses that sell into Britain from abroad. Shein’s UK distribution company alone reported revenue of about £2.05bn for 2024, according to its Companies House filings as reported by Retail Gazette and others, which suggests the Chinese-founded fashion platform would be an obvious candidate for scope once the law is drafted.

How the test treats marketplaces, where millions of items are listed by third-party sellers rather than the platform itself, is one of the most important open questions. The statement speaks of businesses “placing such goods on the market”. Whether a marketplace operator is treated as placing a seller’s goods on the market, or whether the duty falls on each seller, will decide how far the rule reaches into Temu-style and Amazon-style catalogues. The government has not said.

A corner shop, an independent boutique or a small Etsy or eBay seller will not be directly in scope. UKFT, the fashion and textiles trade body, which took part in the government’s forced labour roundtable, notes that “smaller manufacturers and suppliers may face increased information, assurance and due diligence requirements from larger customers seeking to meet their own obligations”.

That knock-on effect is how most small British firms will feel the law. A supplier to John Lewis, Next or M&S, or a brand selling wholesale to a large online retailer, can expect more questionnaires about where cotton, components and packaging come from, and requests for audit reports or supplier lists. Firms that already produce a Modern Slavery Act statement will have a head start.

Why is this happening now?

The immediate pressure has come from Parliament. LBC and Business Live report that the cross-party committee chaired by Liam Byrne has pushed for tougher protections since it questioned Shein in January 2025, when, according to the committee, the company repeatedly refused to confirm whether its products contained cotton from China, including from Xinjiang, where the Uyghur minority are widely believed to be subjected to forced labour.

“For too long, it has been an outrage that our great country which led the abolition of slavery has had weaker defences against forced labour imports than either the EU or the United States,” Byrne said, as quoted by Business Live. “Now, almost two years on from our hearings with Shein, when the firm repeatedly refused to confirm in Parliament whether its products contained cotton from China, including Xinjiang, we have a clear commitment to change the law.”

The same committee has been pressing online platforms on safety more broadly. Earlier this autumn Byrne wrote to two of the biggest names over their reluctance to give evidence, as covered in our report on how MPs pressed Amazon and TikTok to face a marketplace safety hearing.

There is also a trade dimension. In March 2026 the US Trade Representative opened Section 301 investigations into 60 economies over what it called failures to take action on forced labour, and US tariffs followed in July. Business Matters and ESG Today both report that the UK was among the economies targeted. ESG Today notes that the UK review predates those tariffs, but the government’s own statement stresses bringing the UK “in line with key partners”.

The written statement also refers to plans to strengthen the Modern Slavery Act through the Immigration and Asylum Bill, describing them as “an important step” but not enough on their own. The new due diligence law is meant to sit alongside the 2015 Act rather than replace it.

How would a product actually come off sale?

The government has set out a two-part test, and both parts have to be met. First, forced labour has to be identified in the production of the goods. Second, the business placing them on the market has to have failed to meet its due diligence obligations. Only then can the regulator “direct their withdrawal”.

Fieldfisher argues this is an important difference from the EU approach. Its analysis says the EU regulation is “an obligation of result, not an obligation of due diligence”: if a product is made with forced labour, it is banned regardless of how careful the seller was. The UK wording suggests a business that has done proportionate checks could rely on that, at least as the statement is currently framed.

The regulator is unnamed. The statement says only that “a regulator will be empowered”. It could be an existing body handed new powers, or a new one. The Office for Product Safety and Standards already handles product withdrawals for safety reasons, and HMRC and Border Force handle goods at the border, but none of them has been named for this job.

Byrne has made resourcing his main condition. “Now we need a clear timetable, a regulator with the resources to enforce the rules, and meaningful consequences for companies that fail to comply,” he said in remarks reported by Business Live and Business Matters. The government has not published the sanctions that will apply, or whether there will be fines on top of product withdrawal.

Great Britain and Northern Ireland

The goods powers will cover Great Britain only. In Northern Ireland, the government “will apply the EU’s Forced Labour Regulation (EUFLR) under the Windsor Framework”, according to the statement, which says both regimes “aim to deliver a similar effect in practice”. UKFT notes that the EU regulation, Regulation (EU) 2024/3015, applies from 14 December 2027, so businesses that ship to shoppers in Northern Ireland will face the EU’s rules on that date whatever happens to the British bill.

For online retailers that sell UK-wide from one website, that means two different legal tests for the same product, depending on the delivery address. It is the same split that already runs through product labelling and food rules after Brexit.

How does the UK plan compare with the EU and US rules?

The UK has been the odd one out among large Western markets in not having a power to stop forced labour goods being sold. The comparison below sets out the main regimes British retailers and online sellers now have to think about. The UK column reflects the government’s statement only, since no bill has been published.

Regime	Who it covers	What it does	When
UK proposal (HCWS454)	UK firms above £350m global turnover; overseas firms above £350m UK turnover	Mandatory due diligence; regulator can order withdrawal from the GB market if forced labour is found and checks were not done	No date; “as soon as parliamentary time allows”
Modern Slavery Act 2015 (existing)	Organisations with turnover of £36m or more	Annual slavery and human trafficking statement; no duty to act and no product removal	In force since 2015
EU Forced Labour Regulation 2024/3015	Any business of any size placing products on the EU market (and Northern Ireland)	Ban on products made with forced labour; an obligation of result	From 14 December 2027
EU Corporate Sustainability Due Diligence Directive	Companies above EUR 1.5bn turnover (about £1.25bn at current rates), per Fieldfisher	Human rights and environmental due diligence	From 2029, per Fieldfisher
US Tariff Act s.307 and Uyghur Forced Labor Prevention Act	All importers into the US	Import ban at the border; presumption that Xinjiang-linked goods are made with forced labour	In force

Two points stand out. The UK threshold is far lower than the EU’s due diligence directive, as Fieldfisher notes, which could bring more companies into scope here than under the EU law. But the UK’s withdrawal power is narrower than the EU’s ban, because it depends on a due diligence failure. The US system, meanwhile, works at the border; Fieldfisher reads the UK plan as a market prohibition, which would cover goods made in Britain as well as imports.

The Corporate Justice Coalition, which campaigned for the law, has also pointed to the gap between the new £350 million line and the £36 million threshold in the Modern Slavery Act and the Economic Crime and Corporate Transparency Act 2023. On that comparison, many companies that publish a slavery statement today will not face the new duty.

What does it mean for UK shoppers?

For now, nothing changes at the till or in the online basket. There is no bill, no regulator and no date, and the withdrawal power cannot be used until the law exists. Shoppers buying Christmas gifts this year are covered by existing consumer law, not by this plan.

When the law arrives, the effect for most shoppers will be indirect. Large retailers and platforms will be required to know more about where products come from, and in serious cases specific goods could disappear from listings or shelves. The government has not proposed a consumer label, a public register of withdrawn products or a new right to a refund for goods later found to be linked to forced labour.

Will it push up prices?

No impact assessment or cost estimate has been published, so any claim about price rises is speculation at this stage. Big retailers already spend money on supplier audits and ethical trading teams, and the government says the regime will “reflect how responsible businesses already manage risk”. The cost is likely to fall hardest on businesses with long, low-cost supply chains that have done little checking so far.

Shoppers have already seen how weak checks on marketplaces play out in product safety. Consumer group Which? recently found dozens of potentially dangerous items for sale within hours, as set out in our report on unsafe products still on Amazon and eBay and the new law Which? wants. The forced labour plan raises the same question in a different form: who is responsible for what a third-party seller lists.

There is no reliable way for an individual shopper to verify a product’s supply chain from a listing. What shoppers can do is read the Modern Slavery Act statement that larger retailers must publish on their websites, check whether a brand names its factories, and treat very low prices for cotton-heavy goods with some caution. None of these is proof, but they show how seriously a business takes the issue.

What should UK retailers and online sellers do now?

Lawyers advising on the plan say businesses do not need to wait for the bill. Fieldfisher suggests in-scope companies start by reviewing their human rights risk management against the UN Guiding Principles and the OECD Guidelines, since the government has said the law will align with both. Where problems are endemic in a supply chain and cannot be fixed by due diligence, it says firms should look at alternative sources.

1. Work out whether you could be in scope. Check UK and global turnover against £350 million, and remember the treatment of groups is still undecided.
2. Map high-risk inputs. UKFT lists forced and child labour, recruitment practices, wages, migrant workers and subcontracting as relevant risks for textiles, fashion and footwear.
3. Prepare for customer questionnaires. Suppliers to large retailers should expect more information requests, even if they are well below the threshold.
4. Keep your origin records. Invoices, supplier lists and certificates showing where materials come from will matter if a product is ever questioned.
5. Watch the Northern Ireland date. If you deliver to Northern Ireland, the EU regulation applies from 14 December 2027.

Sellers on Amazon UK, eBay, OnBuy and similar platforms are unlikely to be in scope themselves, but platforms that are could pass obligations down through their seller terms. That has already happened with tax: from the Budget, the government is moving responsibility for some sellers’ VAT on to the platforms, as explained in our report on plans to make Amazon and eBay collect sellers’ VAT. A similar pattern for supply chain information, with marketplaces asking sellers for evidence of where goods were made, would not be surprising once the law is drafted, though nothing of the kind has been announced.

Sellers who import from a small number of overseas factories are in the best position to answer such questions, because they know their suppliers. Sellers who buy from wholesalers or dropship from large catalogues may struggle to say where products were made, and should start asking now.

What are critics and campaigners saying?

The plan has been welcomed by campaigners, MPs and the fashion trade body, but each has raised gaps. The Corporate Justice Coalition, the civil society group behind the long campaign for a due diligence law, called the announcement “a landmark step for the UK”. Its co-director Eleanor Rosenbach said: “The announcement today sends a strong message: corporate impunity is coming to an end.”

The coalition objects to two features. The first is the omission of environmental harm, which it says is part of the international standards the UK is aligning with and of the equivalent EU law. “You cannot protect people without also protecting the planet,” Rosenbach said. The second is the £350 million threshold, which it says leaves out many businesses and does not cover the public sector.

Fieldfisher lists a series of unanswered points: how the turnover tests apply to groups, the territorial reach of the duty, which regulator enforces it, what sanctions apply, and whether there will be any route for victims to seek a remedy in the courts. It also asks whether goods could be held while under investigation, as happens in the US, or only removed once an investigation is complete, as in the EU.

For retailers, that last point is the practical one. A power to freeze stock while a case is investigated would be far more disruptive in peak season than a power to order removal at the end of a long process. The government’s statement is silent on it.

Which British fashion and retail names have faced scrutiny?

Supply chain questions have followed UK fashion for years. Business Matters notes that ultra-fast-fashion businesses including Shein and Boohoo have faced scrutiny over their supply chains, and that Shein later abandoned plans for a London listing after regulatory setbacks and criticism of its human rights record.

The issue is not limited to fashion. Business Matters also reports that forced labour claims brought by former migrant workers against Dyson over its Malaysian suppliers are due to go to trial in April 2027, after a High Court ruling in January. That case is a private claim under existing law and is separate from the new regime, but it shows the legal exposure large consumer brands already face.

Value fashion is where the new rules may be tested hardest. Primark, part of Associated British Foods, is one of the largest clothing sellers in Britain; its latest figures are covered in our report on Primark’s annual results and falling profits. Large value chains already run ethical trading programmes, and the new duty would turn that kind of work from voluntary practice into a legal requirement.

What happens next, and when?

The honest answer on timing is that nobody knows. The government says it “will work closely with stakeholders on the design and implementation of these measures and introduce them as soon as parliamentary time allows”. That phrase usually means no bill has been scheduled.

Fieldfisher estimates, based on how long comparable laws such as the Modern Slavery Act 2015 and the Economic Crime and Corporate Transparency Act 2023 took, that Royal Assent could be roughly 12 to 24 months away, depending on when a bill is introduced. Even then, a regulator would need to be set up and guidance written before the withdrawal power could be used.

Date	Event	Status
January 2025	Business and Trade Committee questions Shein on cotton sourcing	Happened
March 2026	US opens Section 301 forced labour probes into 60 economies	Happened; tariffs followed in July
4 November 2026	Written ministerial statement HCWS454 commits to the law	Happened
9 November 2026	Reynolds’ letter to the committee reported; Byrne demands a timetable	Happened
Not set	GOV.UK responsible business guidance hub	Promised
Not set	Bill introduced to Parliament	“As soon as parliamentary time allows”
April 2027	Dyson forced labour claims due at trial (separate case)	Scheduled, per Business Matters
14 December 2027	EU Forced Labour Regulation applies, including in Northern Ireland	Fixed in EU law

The next things to watch are the bill itself, the choice of regulator and any consultation on how the turnover tests and marketplace rules will work. Those details will decide whether the law reaches the third-party listings that make up much of what UK shoppers buy online. The full text of the government’s statement is published on the UK Parliament written statements site.

Frequently asked questions

Is there now a ban on forced labour goods in UK shops?

Not yet. The government has committed to legislate, but no bill has been published and no start date set. Until the law is passed and a regulator is appointed, there is no new power to remove goods from sale in Great Britain.

Which businesses will have to carry out the checks?

UK businesses with a global turnover above £350 million, and non-UK businesses with UK-generated turnover above £350 million. The government has not yet said how the tests apply to groups of companies.

Does it cover online marketplaces such as Amazon, eBay, Shein and Temu?

Business Matters reports that Reynolds’ letter says goods could be removed from online marketplaces as well as shops and warehouses. Large platforms with UK turnover above £350 million look likely to be in scope, but how the duty applies to items listed by third-party sellers has not been explained.

When will the law take effect?

The government says “as soon as parliamentary time allows”. Law firm Fieldfisher estimates Royal Assent could be 12 to 24 months away once a bill is introduced, with a regulator and guidance needed after that.

Will goods be withdrawn just because forced labour is found?

Under the statement, withdrawal depends on two things: forced labour being identified and the business having failed to meet its due diligence obligations. That differs from the EU regulation, which bans forced labour products outright.

What happens in Northern Ireland?

The British goods powers will not apply there. Instead the EU Forced Labour Regulation will apply under the Windsor Framework from 14 December 2027.

Do small shops and online sellers need to do anything?

They are not directly in scope, but suppliers to large retailers should expect more questions about where products and materials come from. Keeping supplier and origin records now will make those requests easier to answer.

Will shoppers get a refund if a product is later withdrawn?

The government has not proposed any new consumer refund right linked to forced labour. Existing rights under the Consumer Rights Act 2015 still apply to faulty or misdescribed goods.

How is this different from the Modern Slavery Act?

The 2015 Act requires organisations with turnover of £36 million or more to publish an annual statement, but it does not require them to act on risks and gives no power to remove products. The new law would add a duty to address risks and a withdrawal power, for a smaller group of larger businesses.