Forced Labour Policy Update
Q&A for CAC Members

The federal government has introduced Bill C-35 to strengthen Canada’s ban on imports produced by forced labour by creating a more formal enforcement framework. Parliamentary debate will resume in September.

The move is largely driven by U.S. pressure, including concerns that Canada is not fully enforcing its current ban. The U.S. is pushing for greater alignment with its own stricter enforcement approach.

Section 301 is a U.S. trade tool used to respond to perceived trade issues. The U.S. has raised the possibility of tariffs (around 10%) on certain Canadian exports, creating real risk for exporters.

Not immediately. However, due diligence is increasingly becoming a requirement to maintain market access, especially through expectations imposed by customers and partners.

Expected areas of focus include stronger enforcement, clearer importer obligations, supply chain verification, and closer alignment with U.S. rules. Much will depend on future regulations.

It could be an improvement if it shifts toward a risk-based approach focused on higher-risk imports rather than broad, prescriptive reporting. This will depend on how regulations are designed.

This is primarily a market access issue. Companies that cannot demonstrate a traceable supply chain may lose business. Requirements will often come indirectly through customers, particularly in the U.S.

• Map key suppliers and inputs
• Keep basic supplier assurances
• Focus on higher-risk areas
• Be ready to respond to information requests
• Engage suppliers early
• Monitor U.S. expectations closely