Summary#

This bill creates the Fighting Against Forced Labour and Child Labour in Supply Chains Act and amends the Customs Tariff. It requires certain federal institutions and large or listed companies to publish yearly reports on steps they take to prevent forced or child labour in their goods and supply chains. It also expands Canada’s import ban to include goods made in whole or in part with child labour, not only forced labour.

• Annual public reports due by May 31 each year from covered federal institutions and entities (Part 1 s.6; Part 2 s.11).
• Who must report: entities listed on a Canadian stock exchange or meeting size tests, and those that import, produce, sell, or distribute goods, or control such entities (s.2 “entity”; Part 2 s.9–10).
• Reports must cover policies, risks, actions, training, and how effectiveness is assessed (Part 1 s.6(2); Part 2 s.11(3)).
• Reports must be posted on the organization’s website; the Minister will also post all reports in a public registry (Part 1 s.8; Part 2 s.13(1); Part 3 s.20).
• Inspectors can verify compliance; the Minister may order corrective action; fines up to CAD $250,000 per offence for non-compliance or false statements (Part 2 s.15, s.18–19).
• Customs Tariff now also bans imports made with child labour, in addition to forced labour (Part 4).

What it means for you#

• Households

  • You can read public reports about companies’ efforts to prevent forced and child labour in their supply chains (Part 3 s.20).
  • The Minister will table an annual summary in Parliament by September 30, which will also be posted online (Part 3 s.22).

• Workers

  • Covered employers must report on employee training about forced and child labour (Part 1 s.6(2)(f); Part 2 s.11(3)(f)).
  • The law does not mandate new workplace standards beyond reporting; it requires disclosure of steps taken, if any (Part 1 s.6; Part 2 s.11).

• Businesses (producers, sellers, distributors, and importers of goods)

  • If you are listed on a Canadian exchange or meet at least two of these in a recent year—assets of at least CAD $20,000,000, revenue of at least CAD $40,000,000, or an average of at least 250 employees—you must file an annual report by May 31 (s.2 “entity”; Part 2 s.11(1), s.11(3)(a)–(g)).
  • Parent companies must report if they control covered entities; control can be direct or indirect (Part 2 s.10; Part 3 s.21(b)).
  • Reports must be approved by the governing body and signed by a board member; joint reports are allowed (Part 2 s.11(4)–(5)).
  • You must post the report prominently on your website and, if federally incorporated, send it to each shareholder with annual financial statements (Part 2 s.13(1)–(2)).
  • Inspectors may enter business premises (not private homes without a warrant), review documents and data, and require assistance (Part 2 s.15–16).
  • Non-compliance, obstruction, or knowingly false statements can lead to fines up to $250,000; directors and officers can be personally liable (Part 2 s.17, s.19).

• Federal government institutions

  • If you produce, purchase, or distribute goods, you must file an annual report by May 31 covering policies, risk areas, remediation steps, training, and effectiveness measures (Part 1 s.6(1)–(2)).
  • You must post the report on your website (Part 1 s.8).

• Provincial, territorial, and municipal governments

  • The Act binds the Crown in right of Canada and of a province (s.4), but the specific “government institution” reporting duty uses the federal Access to Information Act definition, which applies to federal bodies (Part 1 s.3; s.2 “government institution”).

• Importers and retailers

  • Goods mined, made, or produced in whole or in part with child labour, as defined in the Act, are now also prohibited from import, alongside forced labour goods (Part 4; Customs Tariff s.132(1)(m)(i.1); tariff item 9897.00.00).

• Timing

  • Reports are due annually by May 31 (Part 1 s.6; Part 2 s.11).
  • The Act comes into force on January 1 of the year after Royal Assent (Part 5).

Expenses#

Estimated net cost: Data unavailable.

• No fiscal note was published. Data unavailable.
• The Act does not include a direct appropriation; administration costs for inspections, the registry, and annual ministerial reporting are not specified. Data unavailable.
• Maximum penalties: up to CAD $250,000 per offence for non-compliance or knowingly false/misleading statements (Part 2 s.19).
• Compliance costs for entities (e.g., preparing reports, approvals, website posting, shareholder mailings) are not estimated in the Act. Data unavailable.
• Customs enforcement resource needs to apply the expanded import ban are not stated. Data unavailable.

Proponents' View#

• Improves transparency by requiring detailed, public annual reports on policies, risks, actions, training, and effectiveness across supply chains (Part 1 s.6(2); Part 2 s.11(3)).
• Extends Canada’s import ban to cover child labour as well as forced labour, closing a gap in border controls (Part 4; tariff item 9897.00.00).
• Increases accountability: board-level approval and signatures are required; reports must be sent to shareholders for federally incorporated companies (Part 2 s.11(4)–(5), s.13(2)).
• Enables enforcement: inspection powers, corrective orders, and fines up to $250,000, with liability for directors and officers (Part 2 s.15, s.18–19).
• Creates a public registry and an annual ministerial report to Parliament, making it easier to compare organizations and track progress (Part 3 s.20, s.22).
• Aligns with Canada’s commitments under core International Labour Organization conventions by targeting forced and child labour risks (Preamble; Purpose s.3).

Opponents' View#

• Reporting-only model: the Act requires disclosure of steps taken but does not mandate due diligence standards or outcomes; firms could comply with minimal action if they report it (Part 2 s.11(1), s.11(3)).
• Penalties may be too low to deter large firms; the maximum fine of $250,000 per offence may not scale with company size (Part 2 s.19).
• Scope and definitions may create uncertainty until regulations clarify “control” and any prescribed entities (Part 2 s.10; Part 3 s.21(b), (c)).
• Enforcement capacity risk: inspections, registry management, and import enforcement are required, but the Act sets no resources or service standards (Part 2 s.15; Part 3 s.20; Part 4). Data unavailable.
• Compliance burden for mid-sized entities meeting the thresholds may be significant (board approvals, website publication, shareholder mailings), yet the Act provides no streamlined pathway or safe harbor (s.2 “entity”; Part 2 s.11(4)–(6), s.13(2)).
• Potential unintended effects in supply chains if companies end relationships without remediation; the Act asks entities to report any measures to remediate loss of income for vulnerable families, but it does not require such measures (Part 2 s.11(3)(e)).