Introduction

Feedback Forced Labor Ban

Introduction

The Federation of German Industries (BDI) opposes forced labor for three distinct reasons. As a matter of course, we share and want to reiterate stark ethical objections against all forms of work or service which areexacted from any person under the menace of any penalty and which the said person has not offered voluntarily.

As industry association, we want to emphasize two additional reasons for why forced labor should be fought against effectively as well as efficiently. First, forced labor is an indicator for politico-economic instability. Autocratic regimes systematically subdue dissent and opposition. Behind this veil of stability lies – more often than not – a system incapable of channelling societal pressures and interest divergencies. A state that forces parts of its population into modern slavery has its very instability on display and shows publicly that it has no intention of adhering to a set of minimum standards of human rights. For German Industry this is of great concern. Governments flouting basic principles of international law are also likely to break more and other rules that are intended to govern and structure international relations. In times when instability keeps rattling our procurement and target markets, we understand the issue of forced labor as a tripwire indicator of increasing instability to come. Prevalent geopolitical stress makes further destabilization increasingly likely. Therefore, we find that effective incentives should be adopted to prevent further instability in the markets that we rely on economically.

Second and with regards to the single market, German industry understands the issue of forced labor also as one creating competitive disadvantages at the expense of European and German companies globally and within Europe. It is the position of German industry that any form of globalization can work only if economic operators compete on a level playing field. We expect from our trading partners to abstain from measures that distort market pricing. Trade relations should be open, but they should also be reciprocal and fair. Lowering average unit costs by abused, unpaid and forced labor is neither fair, nor should it be rewarded with market access.

As industry association representing exporting as well as importing industry sectors and their businesses, we, therefore, welcome the European Commission’s goal in proposing a regulation on prohibiting products made with forced labor. Since it is our position that such a ban should serve a level playing field, we ask in the following for several changes and improvements so that compliance with the regulation does not create additional competitive disadvantages in trying economic times.