Bill S-211, which came into force in 2024, is fundamentally a transparency and reporting law. It requires certain organizations and government institutions to publicly report on the steps they have taken to identify and address risks of forced and child labour within their supply chains. The legislation was designed to increase public accountability and encourage better corporate practices, but it does not impose mandatory due diligence obligations or create significant new enforcement mechanisms. Bill C-35, introduced in June 2026, is the federal government's response to concerns that Canada's current framework lacks sufficient enforcement tools. Rather than focusing on reporting, Bill C-35 is aimed at strengthening Canada's import ban on goods produced using forced labour. The legislation would provide authorities with stronger powers to investigate supply chains, require supporting documentation from importers, detain goods at the border, and prevent the importation of products where concerns about forced labour cannot be resolved. In practical terms, the Government appears to have concluded that transparency alone is not enough. Bill S-211 tells companies to report on what they are doing, while Bill C-35 seeks to verify and enforce compliance through border controls and enhanced scrutiny of supply chains.
Key Differences
- Bill S-211 is a reporting regime; Bill C-35 is an enforcement regime.
- Bill S-211 requires disclosure; Bill C-35 may require evidence and supply chain tracing information.
- Bill S-211 focuses on corporate transparency; Bill C-35 focuses on preventing goods made with forced labour from entering Canada.
- Bill C-35 would provide CBSA with stronger powers to detain and investigate imported goods.
- Bill C-35 would allow the government to identify specific high-risk goods, regions, or producers that could be subject to additional scrutiny.
Potential CAC Considerations
From a CAC perspective, the principal issue is not the objective of the legislation—which aligns with industry support for eliminating forced labour from supply chains—but rather how the new requirements may be implemented. Previous CAC discussions on Bill S-211 emphasized the importance of practical compliance measures, clear guidance, and avoiding unnecessary duplication. Similar concerns are likely to arise with Bill C-35.
Potential CAC Considerations
- Whether reporting already undertaken for S-211 can be leveraged to satisfy any future C-35 requirements.
- The type of documentation that importers may be required to produce.
- How "high-risk" goods or sourcing regions will be identified.
- Implementation timelines and opportunities for consultation.
- The potential impact on complex agricultural supply chains involving multiple intermediaries and smallholder producers.
Bottom Line
The Government is not replacing Bill S-211 with Bill C-35. Rather, it is attempting to address what it sees as a significant gap in the current framework: the absence of strong enforcement mechanisms. Bill S-211 requires organizations to explain what they are doing to address forced labour risks; Bill C-35 would give the Government greater authority to ensure that goods produced with forced labour do not enter the Canadian market. This Bill will be debated again in the fall session of Parliament before being sent to Committee for review. For CAC members, the key question will be ensuring that any new compliance requirements are practical, risk-based, and complementary to—not duplicative of—the reporting obligations already established under Bill S-211.
