Public consultation on regulatory approach under Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour

Table of contents

• Scope
• Context
• Key questions for input
  • Part 1: General questions
  • Part 2: Information requirements and associated impacts
• Submit your feedback

Scope

Canada has prohibited the importation of goods produced with forced labour since 2020. Building on that foundation, Bill C-35 would strengthen the prohibition by giving Global Affairs Canada the authority to establish the underpinning regulation via a public list of goods at risk of forced labour and the Canada Border Services Agency (CBSA) more effective tools to enforce the regulation. It would allow for a more targeted approach by applying clear obligations to importers of goods where there are reasonable grounds to suspect that the goods were produced wholly or in part by forced labour.

This consultation concerns how that list of goods should be developed and administered. It focuses on the approach, criteria, and processes for identifying goods to be listed and on the information importers of listed goods would be asked to provide. The provisions of Bill C-35 itself are before Parliament and are not the subject of this consultation.

The list of goods is central to that approach, so it is important that it be built in the right way. A credible, well-designed process would:

• protect workers by focusing enforcement where there are reasonable grounds to suspect the use of forced labour;
• treat businesses fairly by giving them clarity and a path to respond;
• align Canada’s approach with international partners who are also working to address forced labour in supply chains.

Your input will help us get the approach right before any goods are listed.

Context

Forced labour presents a distinct enforcement challenge. Unlike many other prohibited goods, products made with forced labour carry no physical indicators that distinguish them at the border.  Unlike Canada’s economic sanctions regime, there is currently no list of goods, producers, or regions, to support proactive, risk-based targeting. Global supply chains are complex and often opaque, and it can be difficult to obtain the detailed production information needed to verify how and where goods were made.

On June 12, 2026, the Government introduced Bill C‑35 to further strengthen the existing forced labour prohibition by establishing a new legislative framework that would enable more effective enforcement of the import prohibition. The proposed legislation would:

• remove the prohibition from the Customs Tariff and establish it in a new, standalone statute;
• authorize the Minister of Foreign Affairs to establish a public list of goods for which there are reasonable grounds to suspect that they are produced, wholly or in part, by forced labour, specifying the producer, the country or region of production, or both, to enable risk‑based enforcement;
• enable information sharing among departments to support the development of the list;
• authorize the making of regulations, including regulations prescribing the information that an importer of listed goods must provide to the Canada Border Services Agency (CBSA) on request;
• replace the existing administrative review mechanisms under the Customs Act with judicial review;
• deem goods to be prohibited from importation where a person requested to provide prescribed information fails to do so; and
• establish cost liability for importers in cases of non‑compliance.

Together, these changes would strengthen Canada’s import ban and reflect approaches taken by key partners.

Key questions for input

Part 1: General questions

These questions relate to the overall approach for identifying and adding entries to the list. The questions are intended to guide your input. You are welcome to address any or all of them, and to raise other considerations you think are relevant to how the list should be developed.

1. Evidence: What sources should Canada rely on to identify goods at risk of forced-labour production?
2. Unit of listing: Under C-35, entries on the list would identify goods specified by producer, countries or regions, or both. What considerations should apply when choosing how to specify a particular good on the list?
3. Relationship to existing measures: How should C-35 complement existing legislative, regulatory, and policy measures to address forced labour in supply chains?
4. Civil society and worker input: What role should civil society organizations, workers, and others with knowledge of supply chains play in identifying goods at risk of forced labour? How can the process enable them to share information effectively, including where those providing it may face risks?
5. Review and delisting: What process should be available for producers and importers to request a review of, or removal of an entry where they believe the association with forced labour no longer applies or was made in error?
6. Effects of listing: What effects should be weighed when deciding whether to list goods, particularly the effects on the workers the prohibition is meant to protect?
7. Implementation supports: What supports would help businesses comply, such as guidance, digital tools, transition periods, and outreach?
8. International alignment: How should Canada's approach relate to those of key partners that are also working to address forced labour and other forms of labour exploitation in supply chains?

Part 2: Information requirements and associated impacts

These questions concern the information that importers of listed goods may be asked to provide.

Drawing from international examples, four models of supply chain tracing information may be considered for a Canadian approach:

• Overall supply chain information: identifies the parties, locations, and stages involved in producing a good, allowing potential forced labour risks to be assessed throughout the supply chain.
• Supplier and entity documentation: verifies the identities and relationships of suppliers, manufacturers, and other entities, helping determine whether there are links to known forced labour concerns.
• Merchandise and transaction records: provides information on the origin, movement, and sale of goods, helping substantiate supply chain claims and trace products back to their source.
• Production and traceability information: links goods and inputs to specific production facilities and processes, enabling verification of where and how goods were produced and whether high-risk sources were involved.

The introduction of information requirements carries both a compliance burden and options for managing it:

• Compliance burden: prescribed information requirements allow for more effective enforcement of the import prohibition, but with associated administrative and financial costs, particularly for businesses with complex global supply chains.
• Measures to manage burden: the burden can be mitigated through measures such as interoperable digital traceability platforms, harmonized reporting templates across jurisdictions, phased implementation based on risk or value thresholds, and safe‑harbour mechanisms for importers with robust due diligence systems.

Discussion questions for information requirements and impacts

You may respond to any or all the questions below and are encouraged to raise any additional considerations that you believe are relevant.

2A - Broad objectives and outcomes

1. What supply chain information and supporting documentation do you currently collect to meet your obligations under the Fighting Against Forced Labour and Child Labour in Supply Chains Act (Supply Chains Act) if applicable?
2. What supply-chain information and supporting documentation should importers of listed goods generally be expected to provide to demonstrate that their goods were not produced, in whole or in part, with forced labour?
3. What types of information (e.g., traceability information, due diligence records, audit documentation) would most effectively support the verification and enforcement of the forced labour import prohibition?

2B - Importer due diligence and compliance expectations

4. What steps are currently taken by importers to ensure the integrity of their supply chains from a forced labour perspective? How do importers ensure that supply chain information received from their suppliers is current and accurate?
5. What documentation should an importer be able to submit to support the removal of specific goods from the list?
6. What timeframe should importers be given to provide the prescribed information after their goods have been listed and a request for information has been issued?
7. How should the Government balance the need for detailed supply chain documentation with the administrative requirements placed on importers, particularly SMEs?

2C - Commodity types and required documents

8. Should the types of documents required from importers vary by commodity or sector? If so, what forms of information is most appropriate for different categories of goods (e.g., raw materials, agricultural products, manufactured goods, or complex products with multi-tier supply chains)?
9. Are certain types of information, such as transaction records, production records, third-party audits, certifications, or worker welfare assessments, more reliable for particular commodities or sectors? If so, please provide examples.
10. For commodities at high risk of forced labour production, what additional production, traceability, or chain-of-custody documentation should importers be expected to provide, beyond standard commercial records?

2D - Information sharing and transparency

11. What information should government publicly disclose regarding forced labour enforcement actions?
12. What role should industry associations play in sharing best practices and risk information?

Submit your feedback

We invite you to submit your feedback in writing to:

Forced Labour / International Security and Political Affairs Branch
Global Affairs Canada
125, Sussex Drive
Ottawa, Ontario, K1A 0G2

Email: forcedlabour-travailforce@international.gc.ca