Canada’s Forced Labour Reporting Will Be Here Soon

Posted by Rob Moore
Blog originally posted on 08/03/2024 07:45 AM


Do you know what you need to do?

Canada’s forced labour and child labour act comes into effect on January 1, 2024, and the responsibility to file a report on your supply chain is due on May 31st, 2024. The act is designed to remove or severely limit products of slave or child labour from the Canadian market.

What does this all mean for you?

Certain importers, exporters, and businesses that meet the criteria set out in the Fighting Against Forced Labour and Child Labour in Supply Chains Act (the Act) must satisfy the reporting requirements.

What businesses are subject to the Act? Those who are:

  • “Producing, selling or distributing goods in Canada or elsewhere
  • Importing into Canada goods produced outside Canada, or
  • Controlling an entity engaged in either of the above activities”

The Act defines an entity as:

  • ‘Is listed on a stock exchange in Canada
  • Has a place of business in Canada, does business in Canada or has assets in Canada and, based on its consolidated financial statements for the last two financial years, has met at least two of the following three conditions:
    • Had at least $20-million Canadian in assets
    • Generated at least $40-million Canadian in revenue
    • Employed an average of at least 250 employees, or
  • Is prescribed by regulations (no “other’ regulations have been made public)”

Reporting is similar to a PIP or CTPAT trade chain review but, rather than a view to security it is pointed at ethical labour practice within the supply chain. Each deemed entity will be required to file a report to the Canadian government. The report should contain certain detail such as:

  • Their general structure, activities, and supply chains
  • Their internal policies in relation to forced and child labour. As well as procedures to relating to identifying and mitigating the use of business partners who may utilize forced and child labour
  • The parts of its business and supply chains carry a risk of forced or child labour being used in the various geographies where it may be prevalent.
  • Steps it has taken to assess, manage, and/or mitigate that risk
  • Internal training provided to employees on forced and child labour
  • Any measures taken to remediate any forced or child labour
  • Internal measures to assess the value of the loss of income to the victims of forced and child labour
  • Internal reports or KPIs to determine the effectiveness of the entity’s policies regarding forced and child labour

Please note the list above is an example of the types of information that could be provided within an entity’s report.

For more guidance, visit Public Safety Canada's website.

The task of ensuring your supply chain is free of forced labour and child labour can seem daunting, but Tradewin is here to help. Our team of experts has the experience and knowledge to assist Canadian businesses in navigating the complexities of the new regulations. We can help you identify your reporting obligations, develop and implement compliance measures, and ensure your reports are accurate and meet all government requirements. Don't wait until the deadline approaches – contact Tradewin today and let us help you ensure your business is compliant with Canada's new forced labour and child labour laws.

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Topics: North America

Blog originally posted on 08/03/2024 07:45 AM

Rob Moore

Written by Rob Moore

As Principal of Consulting for Tradewin's Canadian practice, Rob brings expertise in H.S. Classification, Valuation, North American Free Trade Agreement (NAFTA), Least Developed Country Tariff (LDCT), and General Preferential Tariff (GPT), as well as extensive experience with the automotive and textile industries.