[...] 

Dear Co-Negotiators, Dear Madam, Dear Sir,

We are writing on behalf of the 33 undersigned civil society organisations and trade unions to outline key issues that should be considered during the upcoming trilogues in order to make the proposed EU Forced Labour Regulation (FLR) a success.

1. Remediation: The EU FLR should be worker-centred and include remediation for workers who have experienced forced labour. [...]
2. State-imposed forced labour: State-imposed forced labour should be treated differently from other kinds of forced labour. The Commission’s proposal did not outline any explicit investigative or enforcement measures to address cases of state-imposed forced labour, making it impractical and difficult to investigate and address efficiently such cases at scale. [...]
3. Access to Single-window EU-wide complaints mechanism: The Council and the Parliament have put forward a single-window EU wide complaints mechanism. A single-window mechanism is preferable to the decentralised and fragmented version put forward in the Commission’s proposal. [...]
4. Transparency and the Right to Equal and Informed Participation by Victims/Complainants: The regulation should strike a better balance between commercial confidentiality, due process for companies under investigation, the right to information of complainants, the need to safeguard the victims and survivors from retaliation and public interest. [...]
5. An evidentiary regime adapted to forced labour: Both the European Commission and European Parliament have proposed a high level of evidence to even initiate an investigation (substantiated concern or well-founded reason). The level of proof to initiate an investigation should be lowered as proposed by the Council definition of “substantiated concern” to take into consideration the evidentiary struggles experienced by victims of forced labour who do not have access to all relevant documentation and evidence that may be required during the proceedings. [...]

We thank you for your consideration of these important matters and stand ready to discuss the proposed EU Forced Labour Regulation and the concerns raised in this letter. [...]