Bill C-35: preventing goods made with forced labour from entering the Canadian market

On June 12, 2026, the Government of Canada introduced Bill C‑35, An Act respecting the prohibition of the importation of goods produced by forced labour (Bill C-35). Though Bill C-35 is at first reading and awaiting second reading debate, importers should be evaluating their exposure now.

What you need to know

• Enhanced due diligence. The breadth of the prohibition, which covers any stage of production, requires importers to map and assess forced labour risk across their full supply chains.
• Monitor the “high risk” goods list. Once regulations are published, listed goods will carry disclosure obligations and heightened enforcement scrutiny. Early identification of at-risk product categories is critical.
• Potential for operational disruption: A potential 90-day (or longer) detention of goods creates material supply chain and cost exposure. Any costs incurred by the government in relation to the detention, storage, transportation, or disposal of the goods will render the importer the owner of the goods at the time of importation jointly and severally liable, and such costs will constitute a debt to the Crown.
• Consider interaction with the Supply Chains Act. Organizations with reporting obligations under the Supply Chains Act will want to consider including information regarding their processes and controls established to meet the operational compliance demands of Bill C-35.
• Understand the context. Canada’s approach to forced labour in supply chains has evolved significantly in recent years. Bill S‑211, which came into force on January 1, 2024, introduced annual reporting obligations for certain entities and government institutions. Trade pressures intensified on June 2, 2026, when the United States Trade Representative announced proposed tariffs following investigations into the failure of multiple economies to prevent imports linked to forced labour. Against this backdrop, the Government of Canada introduced Bill C‑35 on June 12, 2026, with the objective of strengthening its existing framework by reinforcing prohibitions on the importation of goods produced with forced labour and advancing its commitments under the Canada-United States-Mexico Agreement (CUSMA).  As renegotiation of CUSMA formally commences, greater enforcement action by Canada under this new legislation may be anticipated. 

What does Bill C-35 prohibit?

Bill C‑35 builds on Canada’s existing customs framework by strengthening restrictions on the importation of goods linked to forced labour. In particular, it would replace and expand the current prohibition under the Customs Tariff, enhancing both clarity and enforcement.

Bill C-35 introduces a prohibition on the importation of goods “produced wholly or in part by forced labour”, with “forced labour” defined by reference to Article 2 of the International Labour Organization’s Forced Labour Convention, 1930 (No. 29)¹.

The term “produced” captures goods that are grown, assembled, manufactured, or mined. This breadth means the prohibition can attach at any stage in a supply chain, from raw material extraction to final assembly.

Bill C‑35 is intended to complement the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Supply Chains Act), which focuses on transparency and reporting obligations. While the Supply Chains Act establishes a disclosure-based regime, Bill C‑35 shifts the emphasis to border enforcement by targeting the importation of goods connected to forced labour (for more on the reporting requirements under the Supply Chains Act, please read our previous bulletin).

A new “high risk goods” listing mechanism

The Minister of Foreign Affairs (the Minister) may establish a regulatory list identifying goods reasonably suspected to be produced by forced labour. Listings may specify the producer, the country or region of production, or both.

This mechanism is significant: while listed goods are not automatically prohibited, importers must provide prescribed information to the Canada Border Services Agency (CBSA) upon request from a customs officer. If the CBSA determines that an importer has not provided the required information, the goods are deemed prohibited. In practice, this would operate as a rebuttable presumption and the importers would bear the burden of demonstrating that their goods are clean. The Minister of Public Safety and Emergency Preparedness, officers or employees of the Canada Border Services Agency, the Minister of Labour, the Minister of Transport, the Minister of Agriculture and Agri-Food, the Minister of Industry, and any other prescribed persons may assist the Minister in establishing this list.

Enforcement powers

• Detention. Customs officers may detain goods for up to 90 days (or longer, if prescribed by regulation) while determining whether they were produced by forced labour.
• Cost liability. Importers and owners of goods imported in contravention of the prohibition are jointly and severally, liable to the government for all costs related to detention, storage, transportation, or disposal.
• Customs Act integration. Contraventions of Bill C-35 are deemed contraventions of the Customs Act, which opens the door to administrative monetary penalties, seizure, and in cases of knowing or wilful non-compliance, potential criminal penalties including fines and imprisonment.
• Narrow recourse. Decisions under Bill C-35 are not subject to appeal, review, re-determination, or further re-determination under the Customs Act. An importer’s sole avenue of challenge is via judicial review under section 18.1 of the Federal Courts Act: a process that generally applies a more deferential standard of review.

What’s next?

Stay tuned for further updates as Bill C-35 advances through Parliament and implementing regulations are proposed.