Thailand

Sourcing risk, regulatory exposure and audit intelligence for Thailand-origin supply chains.

Forced & child labour

Garments listed on ILAB 2024. Seafood/shrimp delisted 2024. Migrant worker recruitment fee exposure remains.

Worker rights & FOA

Freedom of association challenges flagged in ILAB 2024 findings. ILO conventions ratified but inconsistent enforcement.

OHS & audit transparency

Functional audit culture in export manufacturing. Mixed SMETA findings on working hours and wage compliance.

Food & product safety

Functional FDA Thailand. Moderate RASFF alert rate. IUU yellow card lifted 2019 following reforms.

Environmental & regulatory

EUDR low-risk classification (May 2025). IUU yellow card lifted 2019. No active environmental trade restrictions.

Governance & anti-corruption

TI CPI 2024: 35/100. Weak public sector integrity. Corruption risk in customs and regulatory enforcement.

Tariff & preferential access

Standard EU GSP beneficiary. Reduced rates on most categories. No FTA with EU.

Non-tariff barriers

Some products under enhanced controls per Regulation 2019/1793. No sanctions. Standard licensing.

Supply chain traceability

Mixed formal/informal economy in food processing. Multi-tier opacity in seafood supply chains. Improving under regulatory pressure.

Labour & Social Risk

Migrant worker population: ~4–5 million workers from Myanmar, Cambodia, and Laos
Primary audit findings: Working hours, migrant worker documentation, wage compliance
Sectors at risk: Seafood processing, pet food manufacturing, garment
ILO conventions ratified: C029 (Forced Labour), C105 (Abolition of Forced Labour)
US ILAB status: Thai seafood and shrimp listed on List of Goods Produced by Child or Forced Labor

EU Regulatory Exposure

GSP+ status: Thailand lost EU GSP preferences in 2015 due to IUU fishing violations. Standard GSP applies — duty reductions vary by product.
Pet food HS codes: 2309.10 (dog/cat food for retail) — EU MFN duty 8.3%. Under standard GSP a reduced rate applies.
EUDR exposure: Thailand is a sourcing country for palm oil and rubber — both are EUDR-regulated commodities.
Official controls: Thai food exporters subject to EU import checks under Regulation (EU) 2019/1793 — enhanced controls list updated periodically.

Logistics & Supply Chain

Primary export corridor: Gulf of Thailand → Strait of Malacca → Indian Ocean → Suez Canal → EU ports
Key transit chokepoints: Strait of Malacca, Suez Canal
Main EU destination ports: Rotterdam, Hamburg, Felixstowe
Typical transit time: 25–30 days to Northwest Europe
Scope 3 relevance: Long-haul maritime freight from Thailand to Nordics generates approximately 0.8–1.2 kg CO₂e per kg of cargo (sea freight estimate)

Pet Sector Risk Profile

IUU history: Thailand received an EU yellow card in April 2015 for illegal, unreported, and unregulated fishing. The yellow card was lifted in January 2019 following reforms to fishing fleet monitoring, port controls, and catch documentation. Ongoing monitoring applies.
Seafood ingredients: Thai fishmeal, fish oil, and shrimp byproducts are common pet food ingredients. These supply chains carry elevated traceability risk — catch certificate compliance under Regulation (EC) 1005/2008 applies to all imports.
ILAB status: Thai seafood and shrimp remain listed on the US Department of Labor List of Goods Produced by Child or Forced Labor. This creates reputational and due diligence exposure for buyers regardless of EU legal status.
Migrant worker exposure: Seafood processing plants employ high proportions of migrant workers. Documented audit findings include: excessive recruitment fees, working hours violations, wage deductions, and inadequate worker documentation.
CSDDD implication: Companies sourcing Thai seafood ingredients into pet food are within scope for CSDDD value chain due diligence from 2027. Ingredient-level suppliers — including fishmeal and fish oil processors — fall within the definition of upstream business partners.