What are
high-risk products
Also known as: high-risk procurement
High-risk products are goods where there is extensive documentation of systematic violations of fundamental human rights and decent working conditions in the supply chain. In public procurement, contracting authorities across the EU/EEA are increasingly required to identify such products and set specific requirements to mitigate the risk of human rights abuses.
How are high-risk products identified?
The concept is grounded in international frameworks — particularly the ILO core conventions, the UN Guiding Principles on Business and Human Rights, and the OECD Guidelines for Responsible Business Conduct. Products are considered high-risk when their supply chains show documented patterns of forced labour, child labour, discrimination, or suppression of trade union rights.
Common high-risk product categories include:
- Textiles, clothing and footwear — labour exploitation in manufacturing hubs across Asia
- ICT and electronics — conflict minerals and poor working conditions in raw material extraction
- Construction materials — documented violations in mining and production
- Food and agricultural products — forced and child labour in farming and processing
- Chemicals, medical equipment, office supplies and sporting goods
In Norway, DFØ maintains the Høyrisikolisten (High-Risk List), a guidance tool listing product categories with documented risk. At EU level, the Corporate Sustainability Due Diligence Directive (CSDDD) identifies similar high-impact sectors for mandatory due diligence. Certification schemes such as Fairtrade, FSC, GOTS, Rainforest Alliance and TCO Certified can serve as evidence of compliance.
Requirements and contract terms
When procuring high-risk products, contracting authorities should include contract clauses requiring suppliers and subcontractors to ensure goods are produced in accordance with ILO core conventions and relevant national labour legislation. Suppliers are expected to carry out due diligence assessments aligned with the OECD Guidelines for Multinational Enterprises.
Early market engagement is recommended so that suppliers can prepare for these requirements. Tools like Cobrief can help suppliers identify tenders where high-risk product requirements are central, enabling them to prepare compliant bids.
High-risk products are a key focus area within social procurement. By mapping high-risk purchases and setting targeted requirements, public buyers can promote decent working conditions globally while maintaining fair competition.