In your opinion, is it worth switching to Vietnamese textile suppliers if proving forced labour compliance under the new EU rules is just as hard as with China?

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Compliance assessment EU forced-labour rules: switching to Vietnam is not a shortcut — but it can still be worth it Direct answer Yes, it can be worth switching or at least dual-sourcing to Vietnamese textile suppliers — but not because compliance is “easier.” Under the new EU forced-labour regime, the evidentiary burden is broadly similar regardless of country: if a credible forced-labour risk exists anywhere in the supply chain, you must be able to demonstrate robust due diligence and traceability. What Vietnam can realistically give you versus China is mainly: - Lower geopolitical / enforcement heat fewer high-profile forced-labour allegations concentrated in specific regions/sectors, - Better practical auditability/access in many cases, - Potential duty benefits under the EU–Vietnam FTA commercial upside, …but you still need strong upstream traceability cotton → yarn → fabric → cut-make-trim, because Vietnam’s textile chain often includes inputs from third countries including China, which can re-import the same forced-labour risk “through the back door.” What exactly is “the new EU rule” you must design for? - The EU has adopted a product ban instrument: Regulation EU 2024/3015 on prohibiting products made with forced labour on the Union market published in the Official Journal on 12 December 2024. eur-lex.europa.euhttps://eur-lex.europa.eu/eli/reg/2024/3015/oj/eng?utmsource=openai - The Commission communication on the political agreement states the regulation is expected to apply 36 months after publication in the Official Journal i.e., operationally around December 2027, based on the 12 December 2024 OJ publication date. single-market-economy.ec.europa.euhttps://single-market-economy.ec.europa.eu/news/commission-welcomes-political-agreement-ban-products-made-forced-labour-union-market-2024-03-05en?utmsource=openai - Separately, the EU Corporate Sustainability Due Diligence Directive Directive EU 2024/1760 entered into force on 25 July 2024 and sets an EU-wide due diligence framework for large companies with a staged application timeline and later “Omnibus” simplification discussions. commission.europa.euhttps://commission.europa.eu/business-economy-euro/doing-business-eu/corporate-sustainability-due-diligenceen Operational consequence: even if your company is not or not yet directly in-scope of CSDDD thresholds, the forced-labour product ban will still affect you as an importer/distributor because goods can be blocked/withdrawn if linked to forced labour. --- Why Vietnam can still be a good move despite similar proof difficulty 1 Risk profile and investigatory trigger risk The forced-labour ban is country-agnostic, but investigations are inherently risk-based. If your current China sourcing includes categories with persistent forced-labour allegations e.g., certain cotton-related supply chains, your probability of being flagged can be structurally higher than in Vietnam—even though the “proof standard” you must meet is comparable. 2 Auditability and control of subcontracting In practice, many EU buyers achieve better factory access and tighter subcontracting control in Vietnam than in certain China set-ups especially where there is layered outsourcing. That matters because your biggest compliance failure mode is rarely “no policy”; it is unknown subcontracting and opaque tier-2/tier-3. 3 Trade framework leverage EVFTA — helpful, but not a forced-labour shield The EU–Vietnam FTA includes Trade and Sustainable Development commitments, including labour-related commitments referencing ILO core conventions and a structured implementation dialogue. eeas.europa.euhttps://www.eeas.europa.eu/vietnam/the-eu-and-vietnamen?utmsource=openai This is not a legal presumption of “clean supply,” but it can improve: - supplier responsiveness to compliance requirements, - government-to-government engagement environment, - and commercial predictability. --- The key pitfall: Vietnam sourcing can still embed China forced-labour risk upstream If you move Cut-Make-Trim CMT to Vietnam but keep: - yarn from China, or - fabric from China, or - cotton of uncertain provenance, …then from a forced-labour perspective you may have moved the last manufacturing step without removing the highest-risk upstream nodes. So the decision is worth it only if you also redesign upstream controls materials traceability + subcontracting governance. --- Recommended operational stance what I would implement in 30–60 days 1 Treat the EU forced-labour ban as a “customs-stop” risk not a CSR exercise Build an internal file per product family that can be produced quickly if challenged: - full tier mapping at least to spinning/weaving/knitting; ideally to cotton ginning where relevant, - supplier declarations with liability language, - audit summaries + corrective actions, - proof of worker due diligence recruitment fees, grievance channels, employment terms, - transaction-level traceability evidence PO ↔ lot ↔ mill ↔ shipment. 2 Contract structure: ban uncontrolled subcontracting + impose disclosure Embed in the MSA / PO T&Cs: - no subcontracting without written approval, - obligation to disclose all production sites including wet processing, printing, embroidery, - right to audit + right to interview workers, - immediate notification duty if any authority inquiry arises. 3 Materials traceability: require “mill certificates + lot traceability,” not generic COAs For textiles, the practical minimum that works in real disputes is: - named mills spinning + fabric, - lot/batch traceability, - shipping docs that reconcile quantities across tiers. 4 Use Vietnam as part of a diversification + transparency strategy Best practice commercial/compliance outcome: dual-source China + Vietnam while you: - migrate to fewer, larger, more controllable suppliers, - rationalise materials fewer mills, known origins, - and reduce subcontracting layers. --- CBAM note because you tagged it: CBAM is not your driver for textiles CBAM is designed around embedded emissions reporting for specific carbon-intensive goods e.g., cement, iron/steel, aluminium, fertilisers, electricity, hydrogen, not general textile/apparel imports. The Commission’s CBAM implementation guidance is focused on those covered sectors and their reporting logic. commission.europa.euhttps://commission.europa.eu/business-economy-euro/doing-business-eu/corporate-sustainability-due-diligenceen?utmsource=openai So your “Vietnam vs China textile” decision should be driven by forced-labour compliance, duty/lead-time economics, and supply resilience — not CBAM. --- Bottom line recommendation Switching to Vietnamese textile suppliers is worth it if and only if you use the move to gain tighter supply-chain control and upstream traceability. If you simply relocate final assembly to Vietnam while keeping opaque Chinese upstream inputs, your forced-labour compliance burden will remain—and your risk may not drop meaningfully. --- Sources - European Commission — Corporate Sustainability Due Diligence Directive 2024/1760, entered into force 25 July 2024 commission.europa.euhttps://commission.europa.eu/business-economy-euro/doing-business-eu/corporate-sustainability-due-diligenceen - EUR-Lex — Regulation EU 2024/3015 OJ publication 12 December 2024 eur-lex.europa.euhttps://eur-lex.europa.eu/eli/reg/2024/3015/oj/eng?utmsource=openai - European Commission DG GROW — Forced labour ban political agreement; application 36 months after OJ publication single-market-economy.ec.europa.euhttps://single-market-economy.ec.europa.eu/news/commission-welcomes-political-agreement-ban-products-made-forced-labour-union-market-2024-03-05en?utmsource=openai - EEAS — EU–Vietnam FTA, Trade & Sustainable Development chapter and labour commitments eeas.europa.euhttps://www.eeas.europa.eu/vietnam/the-eu-and-vietnamen?utmsource=openai - European Commission TAXUD — CBAM implementation guidance scope/approach focused on CBAM sectors commission.europa.euhttps://commission.europa.eu/business-economy-euro/doing-business-eu/corporate-sustainability-due-diligenceen?utmsource=openai > ⚠️ This analysis is provided for information purposes and does not constitute legal advice. For operations engaging your liability, validate your approach with an EU customs representative and specialised trade compliance counsel.

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In your opinion, is it worth switching to Vietnamese textile suppliers if proving forced labour compliance under the new EU rules is just as hard as with China?

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