Stakeholders urge Ottawa to weigh job losses and retaliation against workers as Bill C-35 import rules take shape
Canada’s plan to tighten its forced labour import ban should account for what happens to workers caught up in enforcement – not only the goods stopped at the border – according to a federal consultation report released this week.
The What We Heard report from Global Affairs Canada summarizes input from 129 participants on regulations supporting Bill C-35, An Act respecting the prohibition of the importation of goods produced by forced labour. Many warned that listing goods could cost workers their jobs or push production to suppliers that are harder to monitor.
Canadian law defines forced labour as work or services provided under circumstances that could reasonably lead a person to believe their safety, or the safety of someone they know, would be threatened if they refused. The definition, set out in the Fighting Against Forced Labour and Child Labour in Supply Chains Act, also covers forced or compulsory labour under an International Labour Organization (ILO) convention – work that is involuntary and exacted under the threat of a penalty.
Anita Anand, Minister of Foreign Affairs, and Patty Hajdu, Minister of Jobs and Families, released the findings in Gatineau, Que., with a second Employment and Social Development Canada (ESDC) report on possible supply chain due diligence rules.
“No one should profit from the exploitation of workers. As Canada diversifies trade and strengthens supply chains, respect for human rights must remain at the centre of those efforts,” Hajdu said in a statement.
The human and business cost of forced labour
About 27.6 million people worldwide are in forced labour, according to ILO estimates cited by Global Affairs Canada.
ESDC describes forced labour as a source of unfair competition that lets producers cut costs by exploiting workers. Canada imported an estimated US$20 billion in goods at risk of modern slavery, according to the 2023 Global Slavery Index from Australia-based human rights group Walk Free.
“Our trade must reflect our values. Canada is committed to ensuring that our supply chains reflect the values we stand for: fairness, accountability and respect for human dignity. The perspectives shared through these consultations will help inform meaningful action to prevent goods produced with forced labour from entering Canada and support a more responsible and equal global trading system,” Anand said.
Why ‘cut and run’ worries labour advocates
The report singles out “cut-and-run” responses, where a buyer drops a supplier once forced labour concerns surface but does nothing to fix the underlying conditions. Participants cautioned that abrupt exits could cost workers income, expose them to retaliation or move production to less visible suppliers without ending the abuse.
Labour and civil society groups urged companies to use their commercial leverage to secure remedy for affected workers.
Some argued remediation should be measured by changes in practice and outcomes, not new policies or supplier commitments.
Worker voice and recruitment debt in forced labour cases
Civil society participants flagged indicators especially relevant to migrant workers, including recruitment-related debt, retention of identity documents and restricted freedom of movement.
Many called for confidential, multilingual channels for workers to submit evidence, with protection against retaliation. Some noted that importers should not be expected to interview vulnerable workers directly.
Industry participants asked that importers showing reasonable efforts not be deemed non-compliant when upstream suppliers withhold records. Others said third-party audits vary in reliability.
What comes next for employers?
HRD Canada has published an explainer on what employers need to know about Canada’s forced labour reporting act, which has required certain entities to report on prevention measures since January 2024.
Public Safety Canada’s 2025 report on the act shows gaps. Of 4,313 reports filed in 2025, 82.3% said they had identified risks or started the process. Only 61.7% of reporting entities said they train employees on forced and child labour, and no compliance orders or charges were issued in 2025.
The companion ESDC report found support for legislation requiring certain entities to identify, prevent and mitigate forced labour risks in their supply chains. Views were divided on letting victims sue in Canadian courts.
HRD Canada covered also Ottawa’s response as the U.S. moved ahead with tariffs targeting forced labour goods, shortly before Canada tabled its tougher forced labour import bill in June 2026.
