Lavoro forzato e importazioni: il Regolamento UE 2024/3015 e gli standard rilevanti dell’Organizzazione Internazionale del Lavoro. Profili critici

This essay intends to introduce a consideration on the scope of EU Regulation 2024/3015 which introduces rules prohibiting economic operators from placing and making available on the EU market or exporting from the EU market products obtained by exploiting forced labor. After an analysis of the essential structure of the Regulation and of his novelty, legally very relevant, relating to the adoption by a European regulatory instrument of a concept directly drawn from the reference ILO Standard (paragraphs 2 and 3), the essay continues with a critical examination of some profiles that are considered particularly relevant: the role of States as perpetrators of forced labor (paragraph 4), the problem of the correctness of the reference estimates (paragraph 5), the absence of a strong consideration of the role of workers and their representatives also as active and eventually sanctioning actors (paragraph 6) and, finally, the problem of the exclusion of transport services.