Compliance in the supply chain

This subtopic brings together materials of relevance relating to compliance with various laws in relation to the supply chain.

Precedents: Supply chain compliance schedule—pro-customer, Supply chain compliance schedule—balanced and Supply chain compliance schedule—short form are for use in business-to-business supply chain contracts when the parties to the agreement wish to detail compliance obligations in a schedule rather than detailing them as clauses in the main body of the agreement. These Precedents include provisions regarding the prevention of bribery, modern slavery, tax evasion facilitation and fraud. Further information on each of these matters can be found below.

Precedent: Compliance with law and regulation clause is a boilerplate clause which can be used in a supply chain contract to set out a general obligation on the parties to comply with laws and regulations.

Bribery

This part of the subtopic considers the key aspects of the Bribery Act 2010 (BA 2010), where the risk of bribery and corruption arises in the supply chain, and how that risk can be managed contractually. Bribery and corruption continue to remain a major issue in world trade, despite dedicated

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Commission publishes Safety Gate report highlighting surge in enforcement action

The European Commission has published its annual report on the Safety Gate Rapid Alert System, recording 4,671 alerts for dangerous non-food products in 2025, a 13% increase on 2024 and the highest annual figure since the system’s launch in 2003. National authorities also notified 5,794 follow-up actions, up 35% year on year, reflecting strengthened cooperation under Regulation (EU) 2023/988 (General Product Safety Regulation). Cosmetics (36%), toys (16%) and electrical appliances (11%) were the most frequently flagged product categories, while dangerous chemicals remained the leading risk, accounting for 53% of alerts, followed by injuries (14%) and choking (9%). Most cosmetics notifications concerned Butylphenyl Methylpropional (BMCHA), a banned synthetic fragrance linked to reproductive harm and skin irritation, and authorities also reported nail polish containing Trimethylbenzoyl Diphenylphosphine Oxide (TPO), banned in 2025 due to risks to prenatal health. Enforcement measures included market withdrawals, border suspensions, removal of online listings and product recalls and in 2025 the Commission’s eSurveillance Webcrawler scanned more than 1.6 million websites, identifying over 20,800 non-compliant products. The Commission states that it will conduct a coordinated product safety ‘sweep’ in 2026 and bring forward further reforms to EU market surveillance rules through a forthcoming European Product Act.

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