{"id":57526,"date":"2026-06-30T10:35:55","date_gmt":"2026-06-30T10:35:55","guid":{"rendered":"https:\/\/my.legal500.com\/developments\/?post_type=legal_developments&p=57526"},"modified":"2026-06-30T10:35:55","modified_gmt":"2026-06-30T10:35:55","slug":"canada-raises-the-bar-on-forced-labour-enforcement-bill-c-35-intensifies-supply-chain-compliance-obligations","status":"publish","type":"legal_developments","link":"https:\/\/my.legal500.com\/developments\/thought-leadership\/canada-raises-the-bar-on-forced-labour-enforcement-bill-c-35-intensifies-supply-chain-compliance-obligations\/","title":{"rendered":"Canada raises the bar on forced labour enforcement: Bill C-35 intensifies supply chain compliance obligations"},"content":{"rendered":"
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Authors:<\/span>Alan Sarhan<\/a>Vasili Moshopoulos<\/a>Genevi\u00e8ve Zinger<\/a>C\u00e9lina Ya\u00efci (Student)<\/div>\n
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On June 2, 2026, the Office of the United States Trade Representative (the USTR) issued a\u00a0Report<\/a>\u00a0under Section 301 of the\u00a0Trade Act of 1974<\/em>, which presented findings that Canada is not effectively enforcing its forced labour import prohibition and has thus burdened U.S. commerce. In light of the findings, the USTR proposed a ten percent tariff on a wide range of Canadian products. The proposed tariff would not apply to goods compliant under the Canada-U.S.-Mexico Agreement.<\/strong><\/p>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n<\/div>\n

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Strengthening the regime: Canada\u2019s response
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\nUnder the\u00a0Customs Tariff<\/em>, Canada has prohibited the importation of goods mined, manufactured, or produced wholly or in part by forced labour since 2020. In practice, the prohibition is enforced at points of entry to Canada by the Canada Border Services Agency (CBSA), which is empowered to detain, seize, and refuse entry to goods where there are reasonable grounds to believe forced labour was involved in their production.<\/p>\n

In the wake of the USTR report and proposed U.S. tariffs, on June 12, 2026, the Canadian government introduced\u00a0Bill C-35 – An Act respecting the prohibition of the importation of goods produced by forced labour<\/a><\/em>, (Bill C-35). Bill C-35 would replace the current import prohibition under the Customs Tariff and would move the Canadian regime toward a more targeted model by allowing listed goods to become subject to prescribed information requirements and by deeming those goods prohibited imports if the requirements are not satisfied.<\/p>\n

More specifically, Bill C-35 would:<\/p>\n