What Did the Canadian Government Announce on October 8, 2026?

Employment and Social Development Canada announced the release of two What We Heard reports prepared following public consultations on forced labour and labour exploitation. The reports collect stakeholder views about how Canada could strengthen its response to products made with forced labour and improve accountability for labour practices across international supply chains.

The first report concerns the proposed regulatory approach under Bill C-35. It examines how the government could identify and list goods suspected of being produced with forced labour and what information importers might be required to provide to demonstrate that their products are not linked to forced labour.

The second report covers potential supply chain due diligence and civil liability measures. It considers whether certain businesses should be required to identify, prevent, mitigate and report on risks of forced labour in their international operations and supply chains. Stakeholders expressed support for some measures but differed on the scope, implementation and potential civil liability provisions.

What Is Canada's Existing Forced Labour Import Ban?

Canada has prohibited the importation of goods produced wholly or partly by forced labour since July 2020. The prohibition was introduced through the Customs Tariff as part of Canada's commitments under the Canada-United States-Mexico Agreement.

This existing prohibition is important because the 2026 policy work is intended to strengthen how the ban is administered and enforced. It is not accurate to say that Canada is introducing its first forced labour import ban in 2026.

The proposed Bill C-35 framework would create a more targeted mechanism for identifying goods that may be associated with forced labour and requesting information from importers. Its objective is to give authorities additional tools to enforce the prohibition more effectively.

Bill C-35: Proposed Changes to Forced Labour Import Rules

The federal government introduced Bill C-35, titled An Act respecting the prohibition of the importation of goods produced by forced labour, in Parliament on June 12, 2026. The bill proposes a standalone legislative framework intended to strengthen the existing import prohibition.

Under the proposed framework, the Minister of Foreign Affairs could establish a public list of goods for which there are reasonable grounds to suspect that they were produced wholly or partly by forced labour. The list could identify the producer, country or region of production, or a combination of these details.

How the proposed listing system could work

1. Identify potential risks: Authorities would assess credible information about products and their supply chains.
2. Develop a public list: Goods meeting the applicable criteria could be identified through a publicly available list under the proposed framework.
3. Request importer information: Importers of listed goods could be required to provide prescribed information to the Canada Border Services Agency (CBSA) when requested.
4. Assess the evidence: Authorities would use the submitted information to determine whether the goods are linked to forced labour.
5. Apply the relevant rules: The proposed framework is intended to support more effective enforcement of the import prohibition.

These steps describe the proposed approach. The final requirements, procedures, timing and legal consequences depend on the legislative and regulatory process.

What Did Businesses Say About the Proposed Import Rules?

The Bill C-35 consultation received feedback from a broad range of stakeholders, including industry and business associations, labour organizations, civil society groups, legal professionals, academics and members of the public. The government reported receiving 73 pieces of written stakeholder feedback alongside input from roundtables.

The report found broad support among participants for strengthening Canada's ability to prevent goods produced with forced labour from entering the Canadian market. However, stakeholders also highlighted practical issues that would need to be addressed when designing the regulations.

Main themes from the consultation

• Clear and reliable evidence: Decisions to list goods should rely on credible, current and corroborated information with a clear connection to the products concerned.
• Transparency and predictability: Businesses want clear criteria, practical guidance and predictable processes for identifying listed goods.
• Procedural fairness: Stakeholders emphasized the importance of opportunities to respond and seek review where appropriate.
• International alignment: Participants encouraged Canada to consider evidence and enforcement approaches used by trusted international partners while retaining the ability to make its own decisions.
• Feasible information requirements: Importers may face difficulties obtaining records from indirect suppliers or upstream producers in complex supply chains.
• Support for smaller businesses: Many participants recognized that small and medium-sized enterprises may need standardized tools, training and proportionate implementation support.

Stakeholders also raised questions about transition periods, digital submission systems, confidential commercial information and how the proposed process would handle essential or time-sensitive goods. These are considerations reported during consultation, not necessarily final government decisions.

Potential Supply Chain Due Diligence and Civil Liability Rules

The second government report examines potential legislation requiring certain Canadian businesses to address labour exploitation in their international operations and supply chains. This is a separate policy area from the proposed list of goods under Bill C-35, although the two measures could complement one another.

A due diligence framework could require covered entities to identify risks, take steps to prevent or mitigate adverse labour impacts, monitor their actions and report on how they address those risks. The final scope of any such legislation, including which businesses would be covered, remains a matter for government policy development and any subsequent legislative process.

What stakeholders supported

The consultation found support for a risk-based approach to due diligence among stakeholders who favoured introducing such measures. Many civil society and academic participants called for alignment with international standards, meaningful engagement with workers, effective remediation and access to remedy for affected people.

Industry participants, businesses and legal professionals also highlighted the need to carefully design any obligations, considering the impact on Canadian companies, implementation costs and the ability to obtain reliable information from complex supply chains.

Why civil liability remains a debated issue

The consultation also examined whether victims of forced labour or labour exploitation should be able to seek damages in Canadian courts against businesses that fail to conduct required due diligence. Views were divided on including this type of civil liability provision. The report records those different perspectives rather than announcing that a new right to sue has already been established.

Canada's Existing Supply Chains Act: What Businesses Must Know

The Fighting Against Forced Labour and Child Labour in Supply Chains Act came into force on January 1, 2024. It establishes annual reporting obligations for certain entities and government institutions concerning steps taken to prevent or reduce the risk that forced labour or child labour is used at any stage of their supply chains.

The existing reporting framework is different from the potential due diligence and civil liability measures discussed in the 2026 consultation. A report describing steps taken to address risks is not automatically equivalent to a comprehensive legal obligation to prevent every instance of forced labour or a new civil liability regime.

Businesses should review their current obligations

• Determine whether the organization meets the existing act's entity and reporting criteria.
• Review annual reporting requirements and applicable filing deadlines.
• Document the organization's structure, activities, suppliers and supply chain risk assessment processes.
• Maintain records of measures taken to prevent or reduce forced labour and child labour risks.
• Check official guidance before making public statements about compliance.
• Monitor Bill C-35 and future announcements about potential due diligence legislation.

Companies should not assume that every Canadian business has the same reporting obligations. Coverage depends on the statutory criteria, and businesses should consult the legislation or obtain qualified legal advice where necessary.

How Canadian Importers Can Prepare for Possible Changes

Even while the proposed framework is being considered, importers can take practical steps to understand their supply chains and prepare for potential future requirements. These steps can also help businesses manage existing legal, operational and reputational risks.

1. Map key suppliers: Identify direct suppliers and, where practical, upstream producers involved in higher-risk products.
2. Collect origin information: Keep accurate product descriptions, country-of-origin records, supplier declarations and relevant purchasing documentation.
3. Assess risk: Consider credible information from government authorities, recognized international organizations and other reliable sources.
4. Set clear supplier expectations: Include appropriate labour standards and documentation requirements in supplier agreements.
5. Keep records organized: Establish a process for retrieving records if authorities request information about a product or shipment.
6. Train relevant teams: Ensure purchasing, customs, logistics and compliance staff understand existing obligations and proposed changes.
7. Monitor official developments: Follow Bill C-35, its parliamentary progress and any regulations or implementation guidance that may be published.

These are practical preparation steps, not a complete statement of legal requirements under Bill C-35. Businesses should obtain professional advice for product-specific or high-risk import decisions.

What Happens Next With Bill C-35?

The October 8 reports are intended to inform the government's continued policy and regulatory work. Global Affairs Canada and the CBSA will consider feedback on the proposed import prohibition framework, while Employment and Social Development Canada will consider feedback concerning potential due diligence and civil liability measures.

The government has stated that Bill C-35 remains before Parliament and may be amended during the parliamentary process. The proposed framework can advance through implementation if the bill receives Royal Assent and its provisions come into force.

Businesses should therefore avoid treating the publication of the reports as confirmation that a public list of goods, new importer information requirements or a new civil liability regime is already operational. Official legislative updates and implementation notices will be important for determining when specific obligations apply.

Frequently Asked Questions

Official Government Resources

• Government of Canada: October 8, 2026 news release — summary of both consultation reports and key findings.
• Global Affairs Canada: Bill C-35 consultation report — stakeholder feedback on the proposed import prohibition framework.
• Employment and Social Development Canada: Due diligence consultation report — findings on potential supply chain due diligence and civil liability measures.
• Parliament of Canada: Bill C-35 — legislative text and parliamentary progress.
• Government of Canada: Forced labour in supply chains — official background and related government information.